Eric Ryan

Eric Ryan

DLA Piper

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Latest Publications


International Tax Alert (US): Tax Court Invalidates Cost Sharing Regulation on Stock-Based Compensation. Now What?

The Tax Court in Altera Corp. v. Commissioner, 145 T.C. No. 3 (2015) has determined that Treas. Reg. §1.482-7(d)(2) requiring related taxpayers to share stock-based compensation (SBC) in a cost sharing arrangement (CSA) is...more

8/14/2015 - Administrative Procedure Act Arm's Length Principle Cost-Sharing Equity Compensation IRS Motion for Summary Judgment Multinationals Notice and Comment Stock Options Stock-Based Compensation Tax Court U.S. Treasury

OECD Discussion Draft on Cost Contribution Arrangements vs. US tax rules on Cost Sharing Arrangements: key comparisons

The OECD has released a Discussion Draft on Cost Contribution Arrangements (CCAs) as part of its ongoing activities related to eliminating Base Erosion and Profit Shifting (BEPS) by multinational enterprises. This...more

5/22/2015 - BEPS Cost-Sharing Discussion Draft Intercompany Transactions International Tax Issues IRS OECD Research and Development Royalties

IRS Releases Its “Roadmap” Of The Transfer Pricing Audit Process

The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process, emphasizing up-front planning and a fact-based approach for examiners. ...more

2/28/2014 - Audits Compliance IRS Transfer Pricing

International Tax News - January 2014

WHEN THE PARTIES WANT AN AGREEMENT TO DISAPPEAR: THE US TAX RESCISSION DOCTRINE - The old saw about the best-laid plans of mice and men also goes for international tax planning and transactions with significant tax...more

1/24/2014 - Corporate Taxes Double Taxation Income Taxes International Tax Issues Value-Added Tax

The US tax rescission doctrine: when the parties want an agreement to disappear

The old saw about the best-laid plans of mice and men also goes for international tax planning and transactions with significant tax consequences. Sometimes the business and/or financial assumptions around the planning...more

1/23/2014 - Cost-Sharing International Tax Issues IRS Rescission

International Tax News - November 2013

US-SWISS VOLUNTARY DISCLOSURE PROGRAM: DEADLINES ARE LOOMING – SWISS BANKS NEED NOT PANIC, BUT MUST ACT SWIFTLY AND THOUGHTFULLY - The recently announced voluntary bank disclosure program between Switzerland and the...more

11/25/2013 - Australia Banks EU Foreign Bank Accounts Income Taxes IRS Tax Evasion Tax Treaty Voluntary Disclosure

Favorable IRS ruling for US taxpayer on application of US - Cyprus tax treaty

In a recent internal legal memorandum (the ILM), the IRS concluded that a US individual was entitled to treat dividends received from a Cypriot holding company with no Cypriot ownership as qualified dividend income (QDI), and...more

11/24/2013 - Dividends EU Income Tax Treaty Income Taxes IRS

The Cyprus crisis and its international tax regime: what multinationals should know

Cyprus has been a member of the European Union since 2004. The country has long been known for its low corporate income tax rate and absence of withholding taxes on payments of interest, dividends and royalties paid to...more

6/6/2013 - Banking Crisis Corporate Taxes Cyprus Bailout EU Income Taxes Multinationals Tax Incentives

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