International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement
Cookies Settings

Is this the end of the US Altera case?

Josh White
November 13, 2019
Share
justice-tp-disputes-600x375

Inter-company transactions between subsidiaries face greater tax exposure after the US Ninth Circuit Court of Appeals denied a rehearing of the Altera case against Internal Revenue Service (IRS).

Unlock this article.

The content you are trying to view is exclusive to our subscribers.

To unlock this article:

Take a Free Trial or Login

Tags

NewsUnited StatesTransfer PricingTax DisputesNorth America Jurisdictions
white-josh-300x300.png
Josh White
Special Projects Editor ITR
Contact
Josh reports on transfer pricing, BEPS, tax disputes and other direct tax matters for ITR’s online and print audience. He covers a range of tax issues in these areas and how companies are dealing with them, as well as the influence of politics on tax developments.
more across site & bottom lb ros

More from across our site

EU - pillar two.jpg
ITR Spring Issue 2023: Editorial
ITR’s latest quarterly PDF is going live today, leading on the EU’s BEFIT initiative and wider tax reforms in the bloc.
Josh White, March 28, 2023
HMRC 2000x.jpeg
COVID behind plunge in UK tax evasion cases, say sources
COVID-19 and an overworked HMRC may have created the ‘perfect storm’ for reduced prosecutions, according to tax professionals.
Courtney Wilson, March 27, 2023
UN large
UN public consultation highlights divisions over global tax policymaking
Participants in the consultation on the UN secretary-general’s report into international tax cooperation are divided – some believe UN-led structures are the way forward, while others want to improve existing ones. Ralph Cunningham reports.
Ralph Cunningham, March 27, 2023
germany berlin reichstag building german parliament bundestag - Concept piece for power, authority, economy, performance, government, planning and control.
This week in tax: Germany publishes corporate minimum tax plan
The German government unveils plans to implement pillar two, while EY is reportedly still divided over ‘Project Everest’.
Josh White, March 24, 2023
Sponsored
planning-3536758.jpg
Building value – ITR’s M&A Guide 2023 launched
With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and tax authorities' responses.
Phil Myers, March 23, 2023
Shanghai is the financial centre of China
UFLPA’s influence on MNEs’ TP comparability analysis in China
Xing Hu, partner at Hui Ye Law Firm in Shanghai, looks at the implications of the US Uyghur Forced Labor Protection Act for TP comparability analysis of China.
Xing Hu, March 23, 2023
Karl Berlin_Ørsted_ITR.jpg
Q&A: Ørsted’s head of tax on the risks to renewables
Karl Berlin talks to Josh White about meeting the Fair Tax standard, the changing burden of country-by-country reporting, and how windfall taxes may hit renewable energy.
Josh White, March 23, 2023
Cancellations driven by COVID-19 are hurting businesses
The tax challenges of global mobility
Sandy Markwick, head of the Tax Director Network (TDN) at Winmark, looks at the challenges of global mobility for tax management.
Sandy Markwick, March 22, 2023
NZ backdrop.jpeg
Why New Zealand’s TP simplification measures are anything but
Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.
Alejandro Ces, March 22, 2023
IRS AND ATO.png
IRS and ATO aim to expand and modernise, say senior officials
In a recent webinar hosted by law firms Greenberg Traurig and Clayton Utz, officials at the IRS and ATO outlined their visions for 2023.
Courtney Wilson, March 21, 2023