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Risks in using transfer pricing studies to support customs valuation

Arent Fox LLP
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USA
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December 6 2012

Earlier this year, the US Government announced that related party imports (i.e., import transactions between affiliates) had for the first time exceeded $1 trillion and have almost doubled in just the last 10 years

Is the timing right for Congress to pass fundamental tax reform?

Arent Fox LLP
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USA
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May 13 2013

Since 1986, there has been no real attempt by Congress to overhaul the American tax system. Recent changes in the economy and projected slower

IRS issues proposed regulations regarding new Medicare tax on investment income: real estate professionals should consider carefully

Arent Fox LLP
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USA
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December 18 2012

Section 1411 of the Internal Revenue Code of 1986 (the “Code”) (added to the Code as part of the Healthcare and Education Reconciliation Act of 2010 (the “Act”) and effective for tax years beginning in 2013) imposes a 3.8 tax on the “Net Investment Income” of individuals and certain other taxpayers whose income exceeds a certain “threshold amount.”

Overview of the American Taxpayer Relief Act of 2012 and some important estate planning opportunities for high net worth individuals

Arent Fox LLP
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USA
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January 9 2013

On January 2, 2013, President Obama signed the American Taxpayer Relief Act of 2012 (the "Act"). While the Act increases income taxes for certain

Medicare cuts offset temporary SGR patch in fiscal cliff bill

Arent Fox LLP
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USA
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January 4 2013

On the first day of 2013, by a vote of 257 to 167, the House of Representatives passed the American Taxpayer Relief Act of 2012 (H.R. 8) preventing tax

In the courts

Arent Fox LLP
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USA
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May 24 2010

On May 13, 2010, the US District Court for the Southern District of California granted in part and denied in part Verizon Wireless's motion to dismiss a consumer's complaint challenging its practice of charging sales tax on the full retail price of telephones, rather than the actual price paid by the consumer

US Senate Budget Committee resolution provides two-year extension of 2009 estate tax levels

Arent Fox LLP
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USA
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April 27 2010

With each passing month, pressure builds on Congress to enact meaningful estate tax reform

Recovery Audit Contractors (RAC): the essentials

Arent Fox LLP
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USA
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June 22 2010

Tax Relief and Health Care Act of 2006, 302, authorized full implementation by 2010 of Medicare post-payment audits of fee for service Part A and B providers by four Recovery Audit Contractors (RACs

Destined for disaster? “Revolutionary” green bond financing for Syracuse mega-project in jeopardy

Arent Fox LLP
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USA
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February 25 2011

Unless you're enjoying an extended President's Day vacation this week, there's a good chance you've already read Rick Moriarty's fantastic piece from last weekend's Syracuse Post-Standard about the latest hurdle facing the developer (Robert Congel) of the star-crossed Destiny USA mega-mall project in Syracuse, New York

Rumored changes to customs valuation treatment of transfer pricing; could impact related party import transactionstransfer pricing

Arent Fox LLP
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USA
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September 8 2010

Recently, word has spread in the importing community that US Customs and Border Protection (CBP) is contemplating changes to the way it interprets the customs valuation statute related to income tax transfer pricing rules for related party pricing, and more specifically, to compensating adjustments

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