There have been a number of significant developments in the area of US tax controversies during 2016. Fenwick & West highlight some of the top US tax cases from this year, including several large § 482 transfer pricing cases that could provide helpful insight for taxpayers who may be facing similar significant transfer pricing adjustments.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
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