News & Analysis as of

Intercompany Transactions Corporate Taxes

Barnea Jaffa Lande & Co.

District Court: Changing a Business Model after Purchasing Company Shares Does not Always Constitute a Tax Event

In May 2022, the Tel Aviv District Court issued an important ruling in the Medingo Ltd case on the tax aspects of business restructuring. This ruling joins a series of previous rulings, in the Gteko case and the Broadcom...more

Miller Nash LLP

Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates

Miller Nash LLP on

Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Drafts Rule Limiting Retroactive Consolidated Filing Elections

The Ohio Department of Taxation has proposed a regulation change that would prevent taxpayers from making a retroactive consolidated filing election for Ohio Commercial Activity Tax purposes (CAT). The rule change appears to...more

Buckingham, Doolittle & Burroughs, LLC

Taxpayer permitted to correct fatal mistake by retroactively making consolidated election for Ohio commercial activity tax and...

The Ohio Board of Tax Appeals recently allowed a taxpayer to retroactively elect to be taxed as a consolidated taxpayer for Ohio commercial activity tax, even after an audit had commenced. Nissan North America, Inc. v....more

Latham & Watkins LLP

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Latham & Watkins LLP on

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Proposed Treasury Regulations Revolutionize Tax Rules Governing Intercompany Financing Transactions"

Recently proposed Treasury regulations, which will likely be finalized this year, promise to alter the tax treatment of a wide range of intercompany financing transactions dramatically, upending nearly a century of law...more

McDermott Will & Emery

Multistate Taxpayers Take Note! Recap of the First Day of the MTC Pricing Summit

McDermott Will & Emery on

On October 6, 2014, the Multistate Tax Commission (MTC) held the first day of a two-day meeting intended to educate state revenue authorities on corporate income tax issues surrounding intercompany transactions, and further...more

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