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Searching Content indexed under Transfer Pricing by Grant Thornton LLP ordered by Published Date Descending.
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IRS Applies New Qualified Liability Rule In Letter Ruling
In a recently released private letter ruling (PLR 201714028), the IRS Office of Chief Counsel determined that liabilities transferred by a taxpayer to a partnership constituted qualified liabilities...
United States
23 Jun 2017
2
IRS Appeals Medtronic Transfer Pricing Loss To Eighth Circuit
The IRS has appealed its loss on in the Tax Court in Medtronic, Inc. v. Commissioner to the Eighth Circuit Court of Appeals.
United States
16 May 2017
3
IRS Rules On Termination Of GRA In Certain Inbound Asset Reorganizations
The IRS released a private letter ruling that held that the acquisition of substantially all the assets of a transferred corporation results in the termination of the associated gain recognition agreement under Section 367.
United States
18 Oct 2016
4
IRS Adds New International Projects To Priority Guidance Plan
The IRS has added and modified several international guidance projects in the 2016‒2017 Priority Guidance Plan.
United States
4 Oct 2016
5
District Of Columbia Court Of Appeals Reverses Summary Judgment Granted To Oil Companies In ‘Chainbridge' Litigation
The DC Court of Appeals held that the Office of Administrative Hearings (OAH) abused its discretion in applying offensive non-mutual collateral estoppel against the DC Office of Tax and Revenue...
United States
26 Aug 2016
6
Proposed Rules Complicate Valuation Discounts On Transfers To Family-Controlled Entities
Treasury and the IRS issued long-anticipated proposed regulations on Aug. 2 that are designed to curb potentially abusive valuation discounts claimed by taxpayers when interests in family-controlled entities are transferred.
United States
19 Aug 2016
7
IRS May Accept Early Country-By-Country Reports
Robert Stack, deputy assistant secretary, International Tax Affairs at the Department of Treasury, recently said that the IRS is working to accept voluntary country-by-country (CbC) reports for the 2016 tax year.
United States
25 May 2016
8
Indiana Tax Court Rules Transfer Pricing Studies Should Be Respected When Determining Indiana Income
On December 18, 2015, the Indiana Tax Court granted a taxpayer's motion for summary judgment and held that the Indiana Department of Revenue improperly adjusted the taxpayer's Indiana source income...
United States
8 Feb 2016
9
IRS Renews Attack On Installment Sales To Grantor Trusts
The IRS has renewed its attack on the transfer tax planning technique in which taxpayers make installment sales to intentionally defective grantor trusts
United States
1 Mar 2014
10
Tax-Sharing Agreement Creates Debtor-Creditor Relationship In Consolidated Group, Bankruptcy Court Says
The U.S. Bankruptcy Court for the District of Delaware recently ruled that a tax-sharing agreement created a debtor-creditor relationship between parties to the agreement.
United States
1 Nov 2013
11
Protecting Your Wealth From Estate And Income Tax Changes
Large tax increases are scheduled to take effect in 2013 unless Congress acts, threatening to drastically alter both transfer tax and income tax rules.
United States
14 Mar 2013
12
District Of Columbia OAH Holds Transfer Pricing Study Is Arbitrary And Unreliable Basis For Determining Reallocation Of Income
The District of Columbia Office of Administrative Hearings has issued an order reversing an assessment that was issued against a software company.
United States
4 Jul 2012
13
IRS Proposes Regulations Under Section 83
The IRS recently proposed regulations (REG-141075-09) under Section 83 to clarify and make changes to the current regulations.
United States
25 Jun 2012
14
Transfer Pricing Ideas: Chinese Trains and Cost-Sharing
The current transfer pricing rules for cost sharing arrangements (CSAs) call for certain "buy-ins" (now called PCTs) when one party makes intangible property available for certain research and development purposes.
United States
11 Jan 2011
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