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International Practice Units - Competent Authority

USA - October 10 2017 In recent months, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has issued a variety of international tax...

Mark P. Thomas.

Focus on Tax Strategies & Developments

Global, OECD - April 27 2017 Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...

Justin G. Crouse.

The Evolving World of Global Tax Planning

Global - January 18 2017 In October 2015, final recommendations on Base Erosion and Profits Shifting (BEPS) were released, setting in motion epochal changes that will impact...

Globalism vs. Populism in the International Tax World

Global, OECD - January 17 2017 Adoption of the base erosion and profit shifting (BEPS) action items in specific countries can be expected to alter traditional multi-national...

IRS Practice Unit Advises Examiners to Use Aggregate Approach in Valuing Outbound Transfers

USA - January 12 2017 On January 4, 2017, the Internal Revenue Service (IRS) released a new "International Practice Unit" (IPU) on the value of intangibles in IRC Section...

Kristina Novak.