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Barbara J. Mantegani

Baker McKenzie

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Final US Regulations on Country-by-Country Reporting Implement OECD BEPS Action 13 for US Multinationals

USA, OECD - July 20 2016 On June 29, 2016, Treasury and the IRS released final regulations (the “Final Regulations”) requiring large US multinational companies to prepare and...

Elizabeth A. Yablonicky, Alexandra Minkovich, Mary C. Bennett, Angela J. Walitt.

IRS Proposes Regulations Implementing Transfer Pricing Country-by-Country Reporting

USA - February 2 2016 On December 21, 2015, Treasury and the IRS released proposed regulations, which will require large U.S. multinational companies to prepare and file a...

Elizabeth A. Yablonicky, Alexandra Minkovich.

North America tax news and developments Volume 15, Issue 4

USA - August 27 2015 On July 27, 2015, the Tax Court ruled in favor of the taxpayer in Altera Corporation & Subsidiaries v. Commissioner, 145 T.C. No. 3, slip op. (2015)...

Kristyn A. Judkins, A. Duane Webber, Elizabeth A. Yablonicky, Joshua D Odintz, Joseph (Jud) B. Judkins.

North America tax news & developments - volume 15, issue 2

USA - April 27 2015 On March 27, 2015, the IRS issued its Annual Report Concerning Advance Pricing Agreements (Announcement 2015-11, I.R.B. 2015-15) (“2014 APA Report”)...

Richard L. Slowinski, Kai R. Kramer, Erin Tyler Brewster, Thomas R. May, Rodney W. Read.