The IRS experiences a significant setback in its efforts to combat so-called corporate tax shelters and alleged
abusive transactions, unexpectedly concedes the inclusion of stock options in cost sharing pool in Seagate, and has acquiesced on the UK petroleum revenue tax in Exxon v Commissioner. By Hal Hicks, David Benson and Margaret O’Connor, Washington DC
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They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
The Brazilian law firm partner warns against going independent too early, considers the weight of political pressure, and tells ITR what makes tax cool