GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
GILTI Conscience Podcast | An In-Depth Look at International Tax in Africa: Part 1
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
Musings on Multinational Tax: What to Expect From GILTI Conscience
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
In today's global economy, characterized by complex supply chains and escalating trade tensions, tariff evasion has emerged as a significant threat to economic stability, fair competition, and government revenue. Traditional...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more
Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane...more
Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more
The current administration’s whipsaw of imposed and withdrawn tariffs continues to rattle financial markets and industries across the United States. In New England, annual trade of goods and services with Canada exceeds...more
Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more
Expert witnesses can be critical to defending a tax position—but what happens when an expert must maintain confidentiality over information that is important to their analysis? Preserving this confidentiality while ensuring a...more
Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime de la charge de la preuve en matière de prix de transfert en présence d'avances consenties sans...more
The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more
The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more
Types of business entities - The most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”), the corporation (“Sociedad Anónima” or “SA”)...more
The rules relating to delegated authority are complex. A taxpayer is well advised to ensure that the scope of a closing agreement the taxpayer signs is what the taxpayer expects, and that an IRS official who signs the...more
24 In this article, we delve into the intricacies of valuing individual legal entities as part of a legal entity rationalization, exploring some of the key considerations that must be considered to prepare a robust and...more
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more
A precise definition of business services was recently at the core of a dispute between the Israel Tax Authority and eBay Marketplace Israel Ltd., a subsidiary of the multinational eBay Group. The district court litigated...more
Welcome to April’s edition of our UK Tax Round Up. This month has seen a number of interesting decisions covering the application of the transfer pricing rules and the unallowable purpose test to an intragroup financing...more
The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing...more
Under a new bill signed into law on March 11, 2024, the South Carolina Department of Revenue will have to satisfy additional standards before it may force affiliated corporate taxpayers to file a unitary combined return. ...more
APMA set a record for executed advance pricing agreements (APAs), but high processing times and a hefty pending APA inventory continued to challenge APMA in 2023. Our Federal & International Tax Group evaluates trends gleaned...more
The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more
1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more
The attractiveness of the United Kingdom as a business location is unabated. There are many advantages to doing business in the UK. Investors can draw on a skilled workforce and access a large market; costs of labour and...more
À la suite de la publication de l’édition 2023 du Guide des prix de transfert à l’usage des PME, l’administration fiscale a mis à jour ses commentaires au BOFiP relatifs aux principes de détermination des prix de transfert...more
The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they ...more
Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more