International Tax ADVISORY: Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas | News & Insights

Advisories April 17, 2017

International Tax Advisory: Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas

Unsurprisingly, the IRS got the same result by trying the same thing. Our International Tax Group analyzes the agency’s latest effort to use a discounted cash flow analysis to audit a cost-sharing agreement.

March 15, 2017

International Tax ADVISORY – IRS Issues Draft Form and Instructions for Country-by-Country Reports

Ultimate parents of U.S. multinational enterprises now have instructions for Form 8975, the U.S. Country-by-Country Report. Our International Tax Group reviews what U.S. MNEs must do to comply with new U.S. filings requirements, as well as procedures for voluntary early filing intended to satisfy BEPS-related Organisation for Economic Co-operation and Development guidance in other jurisdictions. Fixing the reporting mismatch Revenue Procedure 2017-23 The form and instructions Read the full International Tax Advisory here. [...]Read more

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Advisories April 15, 2021

International Tax Advisory: IRS APMA’s Results May Suggest COVID-19 Immunity

Our International Tax Group analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements.

Advisories September 17, 2018

International Tax Advisory: First Round of Proposed GILTI Regulations Avoids the Hard(er) Stuff

The IRS’s opening salvo of proposed regulations under the Tax Cuts and Jobs Act’s global intangible low-taxed income is as complex as you would think. Our International Tax Group cuts through the clutter to address the key takeaways:

Blog Posts May 15, 2017

International Tax ADVISORY – Trump’s Tax Reform Plan When the Dessert Pays for Dinner

President Trump is beginning to follow through on Candidate Trump’s promises to overhaul the tax code. Our International Tax Group examines the few details we have and the path any legislation must take to become law. The opening bid Border tax Path through the Senate Read the full advisory here.

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