Our International Tax Group reviews a pair of tax decisions clarifying the IRS’s ability to cancel advance pricing agreements and how the arm’s-length standard applies to high-value intercompany licensing transactions. ...more
A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more
In a recent decision (Amazon Inc. v. Commissioner, March 23, 2017), the Tax Court handed the IRS an unsurprising loss when it attempted to relitigate many of the same issues it unsuccessfully raised before the Tax Court in...more