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US Tax Court decision has big implications for non-US partners in US partnerships

July 16, 2017

Monte A. Jackel, Senior Counsel at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court's July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .

2017 OECD transfer pricing guidelines released

July 10, 2017

The OECD today released a key update to its transfer pricing guidelines for multinationals. The 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration incorporates new transfer pricing approaches agreed to by OECD and G20 countries in the 2015 base . . .

Israeli court uses flawed logic in key transfer pricing decision

June 29, 2017

Professor Rifat Azam, Radzyner School of Law, Herzliya discusses the Israeli District Court's decision in Getko Ltd vs. Kfar Saba Assessing Officer, which strives to develop transfer pricing principles and guidelines in the Israeli tax law context . . .
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