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On September 23, 2011, U.S. Customs and Border Protection (CBP) posted to its website a request for advance public comments about a proposed revocation of CBP’s ruling HQ 547654 (Nov. 8, 2001). The proposal that CBP is considering would allow the importer that is the subject of the ruling to use transaction value in related party transactions that CBP currently views as having no transaction value. More importantly, it would broaden the definition of what is an objective transfer pricing “formula,” thereby allowing more importers to include post-importation downward price adjustments in their transaction value calculations. For importers of merchandise subject to ad valorem duty, these adjustments could result in significant duty savings.
October 4, 2011
Advisories
October 4, 2011
Advisories
“PPACA, HIPAA and Federal Health Benefit Mandates: Practical Q&A: When Is a Summary More than a Summary: Agencies Issue Long-Awaited Guidance on the ACA’s Uniform Summary of Benefits and Coverage Requirement,” The Self-Insurer, October 2011.
October 2011
Publications
"Strengthening Public Hospital Governance," a Special Commentary in "Dynamic Governance: An Analysis of Board Structure and Practices in a Shifting Industry," The Governance Institute, Fall 2011 (with J. Rice).
Fall 2011
Publications
“Interpreting Section 546(e) Safe Harbor Post-Enron,” Law360, September 20, 2011.
September 20, 2011
Publications
"Uncertainty on REITs Stalls Housing Market," American Banker, September 15, 2011.
September 15, 2011
Publications
“The Annual Stop Tax Haven Abuse Act Show,” Tax Management International Journal, Vol. 40, No.9, September 9, 2011.
September 9, 2011
Publications
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