Cym H. Lowell

Cym H. Lowell

McDermott Will & Emery

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Focus on Tax Controversy - Spring 2014

Company Jet Audit Issues: A Word to the Wise - Once a business attains a certain level of success, an aircraft often becomes a valued asset. Public and closely held private companies alike find that the use of a...more

3/18/2014 - Aircraft Audits Corporate Taxes IRS

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

Multilateral Advance Pricing Agreements

As transfer pricing examination and controversy continue to grow, it’s becoming increasingly common for a multinational enterprise group to have advance pricing agreements (APA) with more than two countries (typically...more

1/16/2013 - Advance Pricing Arrangement Program 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 - Multinationals 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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