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European Union
Mayer Brown
The European Commission has repeatedly expressed its ambition to implement the Two-Pillar agreement in a coherent and consistent way across Member States. On December 22, 2021, a mere two days after the Inclusive Framework released its Pillar Two package.
United States
Ruchelman PLLC
The purpose of the most recent decision in the Medtronic saga extends and refines the prior analysis of one of five connected controlled transactions within Medtronic's controlled group of multinational medical device producers and suppliers.
Freeman Law
International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting...
Blue J Legal
As a tax practice, how do you bring joy to your clients' lives.
Freeman Law
This opinion regards a transfer pricing, comparable uncontrolled transaction.
Cadwalader, Wickersham & Taft LLP
The background to the case was the prominent acquisition by BlackRock, in 2009, of the unrelated North American operations of Barclay Global Investors.
Mayer Brown
At a recent conference, individuals from the U.S. Treasury were very explicit in their desire to receive comments on the Progress Report on Amount A of Pillar One, which was released by the OECD on July 11, 2022.
Mayer Brown
In 2022, we foresee several trends and developments that will converge to substantially impact tax controversies in the United States.
Mayer Brown
In 2018, the IRS reminded exam teams to perform a "diligent penalty analysis" in every transfer pricing case. Since then, we have observed that the agency is increasingly...
Mayer Brown
On May 27, 2022, the OECD released two public consultation documents related to the tax certainty aspects of Amount A.
Mayer Brown
On May 27, 2022, the OECD released two public consultation documents related to the tax certainty aspects of Amount A.
Mayer Brown
In April, the IRS released a practice unit on country-by-country (or "CbC") reporting. The purpose of the document is twofold: (i) describe the background of CbC reporting...
Mayer Brown
On March 22, 2022, the Internal Revenue Service's Advance Pricing and Mutual Agreement Program released its 2021 Announcement and Report Concerning Advance Pricing Agreements.
Alston & Bird
Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges...
Davies Ward Phillips & Vineberg
Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th president of the United States.
Fenwick
In their latest installment of U.S. Tax Review, co-authors James Fuller, Larissa Neuman and Julia Ushakova-Stein examine recent OECD developments, ...
Mayer Brown
On January 20, 2022, the OECD released the latest version of its OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Freeman Law
Created by Congress in 1971 as a tax incentive for domestic exporters of U.S.-made goods, the domestic international sales corporation (DISC) remains a viable tool...
Mayer Brown
Intellectual property is one of the key drivers of profitability for a multinational company. Because IP is inherently mobile, tax planning for IP routinely involves intercompany licensing...
Mayer Brown
In ancient Rome, a college of "augurs" would predict the future by observing the flight patterns of birds, examining the entrails of animal sacrifices, or interpreting natural phenomena. While perhaps less colorful, ...
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