Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
See: Steptoe & Johnson.
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about difficulties applying the House GOP's destination-based cash flow proposal to partners and partnerships . . . .
US Senators Bernie Sanders (I-Vt.) and Brian Schatz (D-Hawaii) today introduced a tax bill designed to curtail . . .
Paul L. Caron has been named dean of Pepperdine School of Law, Pepperdine University has . . .
Mindy Herzfeld has joined Ivins, Phillips & Barker's corporate and international tax groups located in Washington DC, the firm . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses President Trump's executive order mandating that for every new regulation issued, two must be removed, noting that it will be very difficult to apply this order to US tax regulations . . .
See: Steptoe & Johnson
JP Canavan discusses newly released draft instructions to US Form 8975, which include information on early country-by-country reporting for US-parented MNEs and on how to report 'stateless' constituent entities . . . . . .
See: Start Making Sense.
See: Bloomberg BNA.
Ukraine and the US have signed a Model 1 FATCA intergovernmental agreement (IGA) according to an . . .
Eli Miller will serve as US Treasury Chief of Staff, newly appointed US Secretary of the Treasury, Steven T. Mnuchin, announced . . .