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Tax Planning Transfer Pricing International Tax Issues

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

Morgan Lewis on

Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses

Fox Rothschild LLP on

The Trump administration’s fluctuating tariffs pose major compliance risks for businesses operating in the U.S. Dive into the challenges they pose to businesses that rely on imported goods and services as Marina Gentile...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion

“GILTI Conscience” takes on the world of high-fashion, as Skadden tax partner and host David Farhat is joined by associate Stefane Victor and Giuseppe Abatista, vice president at Banca Popolare di Puglia e Basilicata, as they...more

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more

McDermott Will & Schulte

IRS Roundup March 15 – March 28, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more

Allen Barron, Inc.

International Business Dealings Require Integrated Legal, Tax and Accounting Support

Allen Barron, Inc. on

Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more

Proskauer Rose LLP

UK Tax Round Up - February 2025

Proskauer Rose LLP on

Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

Morgan Lewis

Key Takeaways: US-Canada Transfer Pricing & Tax Controversies: What’s New, What’s Not, and How to Prepare for Both

Morgan Lewis on

The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more

A&O Shearman

Amount B or not to be? The OECD’s Pillar One Amount B report

A&O Shearman on

The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more

Mayer Brown

Mise à jour de la doctrine administrative relative aux prix de transfert

Mayer Brown on

À la suite de la publication de l’édition 2023 du Guide des prix de transfert à l’usage des PME, l’administration fiscale a mis à jour ses commentaires au BOFiP relatifs aux principes de détermination des prix de transfert...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing

For law students or young practitioners pursuing a career in tax law, there are numerous possibilities to gain hands on experience and knowledge. However, learning about and finding an entry into transfer pricing may be much...more

Freeman Law

Gain Recognition Agreements and Outbound Stock Transfers

Freeman Law on

GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

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,...more

Freeman Law

[Webinar] The Freeman Law International Tax Symposium - October 20th - 21st, 9:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more

Miller Nash LLP

Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates

Miller Nash LLP on

Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more

Miller Nash LLP

Today in Tax: Three Questions You Should Be Asking If You Have Overseas Affiliates

Miller Nash LLP on

US companies often have commercial transactions with their overseas affiliates in the form of financing, supply, manufacturing, services, or other agreements. Each of these common intercompany transactions can be the cause of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Multinationals Should Consider Adding ‘Competent Authority Processes’ to Their Tax Strategies

Takeaways - Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized. The “competent authority...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Proskauer - Tax Talks

Court of Appeal overturns High Court and holds that tax claim notice was valid

Proskauer - Tax Talks on

This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer...more

McDermott Will & Schulte

[Webinar] Novità Fiscali Fine 2020 - January 21st, 3:00 pm - 5:00 pm CET

Proseguendo una consuetudine dello Studio, che ha sempre raccolto l’interesse e l’approvazione da parte Vostra, abbiamo organizzato, quest’anno in formato webinar, un incontro sulle principali novità fiscali recentemente...more

McDermott Will & Schulte

[Webinar] Tax News At The End Of 2020 - January 21st, 3:00 pm - 5:00 pm CET

Continuing a practice of the Firm, which has always garnered your interest and approval, we have organized, this year in webinar format, a meeting on the main tax innovations recently introduced and of interest to businesses....more

Proskauer Rose LLP

UK Tax Round Up - December 2020

Proskauer Rose LLP on

COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

Proskauer - Tax Talks on

In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Hogan Lovells

Tech Tax – Looking Forward to 2020

Hogan Lovells on

Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more

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