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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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment