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Transfer Pricing
United States
Mayer Brown
In a recent case, Villa-Arce v. Commissioner, a whistleblower sent information to the IRS that he believed showed that the company was using improper transfer pricing practices and taking unjustified deductions.
Mayer Brown
Last week, the IRS released a mysterious new audit "campaign" that may implicate – inadvertently or otherwise – transfer pricing practices.
Mayer Brown
Can the IRS sue a corporation because it believes the company underreported its taxes? You might think the answer is no — the IRS must first propose an adjustment...
Mayer Brown
On July 21, 2023, the Internal Revenue Service ("IRS") released Notice 2023-55 (the "Notice") providing temporary relief from the final foreign tax credit regulations issued in 2022 (the "2022 Final Regulations").
Caplin & Drysdale
One key component of the OECD's Pillar One proposal to reallocate taxing rights from producer to consumer nations is the promise that businesses and governments...
On May 23 the Tax Court ordered Medtronic and the IRS to file a stipulated decision stating that the resolution of Medtronic's transfer pricing case does not preclude Medtronic from seeking future foreign tax credits...
Shulman Rogers
The IRS has made it clear publicly that it will increase efforts to identify tax fraud and underpayments by individuals and businesses with annual income of more than $400,000.
Steptoe & Johnson
The Tax Cuts and Jobs Act (TCJA) was hastily enacted and ushered in a sea change to how the U.S. imposes tax on international operations; it was inevitable that litigation...
The U.S. government may have avoided a challenge to a controversial section 78 regulation by issuing the taxpayer a refund. In Kyocera, 1 the taxpayer challenged the validity of a regulation...
Cooley LLP
Many overseas companies reorganize or "flip" to create a US parent company or to access US venture financing and customers.
Holland & Knight
The IRS has announced new rules relating to the acceptance of Advance Pricing Agreement (APA) and renewal requests.
Caplin & Drysdale
Clark Armitage and Elizabeth Stevens offer insights in Indepth Feature: Transfer Pricing for the May 2023 issue of Financier Worldwide Magazine.
Ruchelman PLLC
Regardless of their political affiliations, presidential administrations and members of Congress share the goal of maintaining U.S. competitiveness on the global market.
Mayer Brown
Transfer pricing audits by the IRS can take years to resolve and consume tremendous resources. Mayer Brown's Jenny Austin, Jason Osborn, and May Chow explain how preparation, patience...
Caplin & Drysdale
The IRS's plan to be more selective about which companies apply for advance approval of their transfer pricing transactions could shorten the application process...
Mayer Brown
This week, the FASB issued an amendment to a previously proposed Accounting Standards Update that would
Davies Ward Phillips & Vineberg
As we settle into the new year, let's take a moment to first consider last year's tax developments and then take a look ahead to what 2023 might have in store for us.
Mayer Brown
On February 1, 2023, the OECD Forum on Tax Administration published its Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements.
Caplin & Drysdale
Clark Armitage offers his insights in Roundtable: Transfer Pricing for the February 2023 issue of Financier Worldwide Magazine.
Freeman Law
In 1964, the Mexican government introduced Maquiladoras as a strategy to attract foreign investment and increase industrialization on the Mexican border. Maquiladora's process, produce, transform...
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