The IRS’ Action on Decision (AOD), on November 10 2010, stating it does not agree with the result or reasoning of the US Tax Court’s decision in Veritas Software Corp. v. Commissioner, brought a spectrum of transfer pricing conflicts to light as the US Tax Court and IRS struggle to find common ground.
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From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency