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New regulations address outbound transfers and transfer pricing

USA - September 21 2015 On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under...

Moshe Spinowitz, Paul W. Oosterhuis, Nathaniel Carden, Hal Hicks, B. Chase Wink.


IRS implements final changes to advance pricing agreement process

USA - September 2 2015 On August 12, 2015, the IRS issued Rev. Proc. 2015-41, which sets out the procedures for pursuing advance pricing agreements (APAs). The new revenue...

Robert H. Green, Matthew S. Kramer.


IRS implements final changes to competent authority process

USA - September 2 2015 On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning...

Robert H. Green, Matthew S. Kramer.


Tax Court invalidates stock-based compensation amendment in Altera

USA - August 3 2015 On July 27, 2015, the U.S. Tax Court, in Altera Corp. and Subsidiaries v. Commissioner, 145 T.C. No. 3, invalidated a 2003 amendment to Treas. Reg...

Nathaniel Carden, Edward Lam, Matthew S. Kramer.


Appeals court reverses IRS-favorable Tax Court decision in BMC Software

USA - March 18 2015 On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable...

Nathaniel Carden, Eric B. Sensenbrenner, Julia M. Kazaks.