The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more
6/21/2019
/ Advanced Pricing Agreements ,
Business Entities ,
Corporate Counsel ,
Corporate Taxes ,
Cost-Sharing ,
Income Taxes ,
Intangible Property ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Multinationals ,
Offshore Companies ,
Section 482 ,
Stock-Based Compensation ,
Tax Court
Traditionally, in the world of international tax planning, it has not been uncommon to see corporate structures utilizing entities organized in offshore jurisdictions that do not impose an income tax on corporate earnings –...more
4/30/2019
/ BEPS ,
British Virgin Islands ,
Cayman Islands ,
Corporate Structures ,
Corporate Taxes ,
Economic Substance Doctrine ,
GILTI tax ,
International Tax Issues ,
Jurisdiction ,
Multinationals ,
Offshore Companies
Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more
In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more
3/3/2017
/ AbbVie ,
Capital Losses ,
Inversion ,
IRS ,
Offshore Companies ,
Pharmaceutical Industry ,
Shareholder Votes ,
Stocks ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Termination Payments