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Corporate Taxes Arms Length Transactions

Rivkin Radler LLP

Not Selling Despite Tax Increases? Review the Buy-Sell Agreement Among Owners

Rivkin Radler LLP on

Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more

Jones Day

JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision

Jones Day on

The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more

International Lawyers Network

Establishing A Business Entity In Latvia (Updated)

1. Types of Business Entities - Foreign investors may choose from the types of business entities: - Limited liability company - Joint stock company - Individual merchant - General partnership - Limited...more

McDermott Will & Emery

IRS Announces More LB&I Campaigns!

McDermott Will & Emery on

The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more

International Lawyers Network

Establishing A Business Entity In Latvia

1. Types of Business Entities - Foreign investors may choose from the types of business entities: • Limited liability company • Joint stock company • Individual merchant • General partnership • Limited liability...more

Bracewell LLP

Proposed Regulations on Immediate Expensing Provide Greater Clarity for the Energy Industry

Bracewell LLP on

On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit Upholds Validity of Cost-Sharing Regulations that Stray from Arm's-Length Standard

On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more

Foley & Lardner LLP

Tax Act Sweetens the Pot for Corporate Divestitures

Foley & Lardner LLP on

The Tax Cuts and Jobs Act of 2017 contains some of the most significant changes in tax laws in more than a generation. While the full implications of the Tax Act are still coming into focus, the magnitude of these changes...more

Jones Day

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

McDermott Will & Emery

MTC Arm’s-Length Adjustment Service (Part II): “An Expression of Grief, Pity, or Concern”

McDermott Will & Emery on

Executive Summary - ..Multistate Tax Commission (MTC) transfer pricing program moving forward in some fashion; ..Priority includes information sharing among participating states (and possibly their third party...more

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