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Proposed Regulations Under Section 956

USA - November 7 2018 Corporate taxpayers that own interests in controlled foreign corporations ("CFCs") should be aware that proposed regulations issued on October 31...

Jonathan S. Brenner, Josiah Child.

Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership

USA - April 5 2016 In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require...

Kirsten Burmester, Michael G. Pfeifer, Scott D. Michel, J. Clark Armitage.

The final OECD BEPS tome has arrived

OECD, Global - October 8 2015 Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting (BEPS) on...

Patricia Gimbel Lewis, Kirsten Burmester, Neal M. Kochman, J. Clark Armitage, Peter A. Barnes.

Transfer pricing audits: flipping the tested party

USA - August 13 2015 In some recent transfer pricing audits, the Internal Revenue Service (IRS) "flipped the tested party" after examining transactions between related U...

Patricia Gimbel Lewis, Elizabeth J. Stevens, Neal M. Kochman, Mark D. Allison, J. Clark Armitage, Peter A. Barnes.

IRS releases guidelines for examining CFC transactions

USA - July 29 2015 On July 17, 2015, the Internal Revenue Service (IRS) released three new "practice units," each examining a particular type of transaction involving a...

Patricia Gimbel Lewis, Elizabeth J. Stevens, Neal M. Kochman, Mark D. Allison, J. Clark Armitage, Peter A. Barnes.