It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more
India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more