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
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.
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
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
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
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
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
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