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A. Tracy Gomes

A. Tracy Gomes

McDermott Will & Emery


Latest Publications

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India at the Crossroads

India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more

3/26/2013 - Corporate Taxes Double Taxation Economic Development Foreign Investment Multinationals Tax Reform Transfer Pricing Vodafone

Russian Transfer Pricing Law

Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more

2/26/2013 - Advance Pricing Arrangement Program Annual Filings Audits International Tax Issues OECD Penalties Required Documentation Transfer Pricing

Worthless Stock Deductions: Valuation, Transfer Pricing and Technical Considerations

When a multinational enterprise (MNE) has affiliates that have become insolvent, the overall tax planning objective frequently is to secure a U.S. tax deduction (often ordinary) for worthless stock or debt. The essential...more

12/7/2012 - Multinational Enterprise Transfer Pricing Valuation Worthless Stock

Effective Resolution of BRICS Country Transfer Pricing Disputes

In the evolving world of international transfer pricing, it can be risky to assume that planning strategies to achieve the lowest possible effective tax rates, as encouraged by the operative provisions of the Organisation for...more

11/12/2012

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