• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

transfer pricing

International Tax ADVISORY: Big Tax Court Win for Eaton in Canceled APA Case

August 15, 2017 By Henry Birnkrant and Stefanie Kavanagh

The IRS abused its discretion when it canceled two advance pricing agreements. Our International Tax Group covers Eaton’s victory in the Tax Court and how it allays concerns about how worthwhile an APA can be. Public and judicial scrutiny Standard of review Where do we go from here? Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: APA, APA case, Eaton Corp, IRS, Tax Court, TPM, transfer pricing, transfer pricing method

Proposed Sec. 367 Regs Say Goodbye to Goodwill Exception

November 23, 2015 By Heather Ripley

Citing aggressive taxpayer positions, recently proposed regulations do away with the foreign goodwill exception to gain or income recognition for outbound transfers under Section 367. The rules also restrict the type of property eligible for the active business exception. Reasons for Change Per the preamble, taxpayers interpret Section 367 and the regulations in one of two ways when claiming favorable treatment of foreign goodwill and going concern value. One interpretation argues that goodwill and going concern value are not IP within the meaning of Section 936(h)(3)(B) and thus not subject [...]Read more

Filed Under: International - Corporate Tax Planning, International - Outbound, International - Transfer Pricing, International Tax Advisory, Mergers and Acquisitions - International Tagged With: active business exception, Corporate Tax Planning, foreign corporation, foreign goodwill exception, goodwill, intangible property, IRS, outbound, proposed regulations, Section 367, section 482, temporary regulations, transfer pricing

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FDII Gift cards GILTI international tax IRA IRAs IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • Top Unclaimed Property Regulatory and Enforcement Challenges in 2021
  • If at First You Don’t Succeed, Try, Try Again to Enact the Nation’s First Digital Advertising Services Tax
  • Digital Services Taxes and Nexus for Foreign Tax Credit Purposes
  • FAQs on Unclaimed Property Aspects of Retirement Assets
  • UP Front: A 2021 Sightline for Unclaimed Property Professionals

Archives

Copyright © 2021 · Alston & Bird · All Rights Reserved. Privacy.
This website uses cookies to improve functionality and performance. By continuing to browse this site, you are consenting to the use of cookies on this website. OkCookie policy