Gregory J. Hartker

Gregory J. Hartker

K&L Gates LLP

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The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

2/21/2014 - Foreign Tax IRS Tax Credits Transfer Pricing

The San Francisco Proposition E Gross Receipts Tax Ordinance: A Mixed Bag for Investment Fund Managers

On November 6, 2012, San Francisco residents approved Proposition E (the “Gross Receipts Tax Ordinance”) instituting a new gross receipts tax to replace the City’s 1.5% payroll tax. The new gross receipts tax is phased in...more

11/19/2012

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