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A 360-Degree View: October and November 2017


By on Nov 6, 2017
Posted In Uncategorized

Wrapping Up October – and Looking Forward to November As we wrap up October, you can view all of the topics we discussed over the last month and take a look at the upcoming tax controversy events where our lawyers will be speaking in November. Upcoming Tax Controversy Activities in November: November 10, 2017: Robin...

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‘Medtronic v. Commissioner’: A Taxpayer Win on Transfer Pricing, Commensurate with Income, and Section 367 Issues


By on Nov 9, 2016
Posted In Alternative Dispute Resolution, Court Procedure Matters, IRS Audits, Transfer Pricing Resource, Trial Courts, Uncategorized

On June 9, 2016, the US Tax Court released its opinion in Medtronic, Inc. and Consolidated Subsidiaries v. Commissioner. The Internal Revenue Service had taken issue with the transfer pricing of transactions between Medtronic, Inc. and its Puerto Rican manufacturing arm under §482 of the Internal Revenue Code. Finding the IRS’s application of the comparable profits...

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UK Government Confirms Introduction of New Cap on Interest Deductibility


By on Sep 20, 2016
Posted In Transfer Pricing Resource, Uncategorized

The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of their net interest expense to EBITDA. The new rule will apply from 1 April 2017,...

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ABA Seeks Priority Guidance for Transfer Pricing Issues


By on Jun 7, 2016
Posted In Court Procedure Matters, Transfer Pricing Resource, Uncategorized

The ABA recently issued comments to the IRS and Treasury regarding the new temporary regulations issued in TD 9738 concerning the aggregation of controlled transactions, under Section 482, which broaden (“clarify”) the scope of intangible value, to include “all the value provided” from a controlled transaction, and such other transactions that may occur before, during or...

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