Arm's Length Principle Vs. Implicit Support: What's the Way Forward?
The Multistate Tax Commission (MTC) held its annual Fall Meetings in Little Rock, Arkansas (Eversheds Sutherland attorneys attended the event, and a full report will be provided). On Thursday, November 17, the MTC's Executive...more
After a 4 1/2 year hiatus, the Multistate Tax Commission has met to revive the State Intercompany Transactions Advisory Service Committee (SITAS). Matt Hunsaker talks about the committee meeting and other recent happenings in...more
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more