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The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
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Sponsored by Deloitte USIncreased globalisation has resulted in significant pressure on US multinationals to take a more global view not only of their operations but also of the manner in which they hold, manage, and develop intangible assets. As a result of these drivers, transferring intangible property (IP) out of the US group to a controlled foreign corporation (CFC) may make sense, explain David Cordova, Gretchen Sierra and Douglas Cowan. -
Sponsored by Deloitte USMarco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.
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Sponsored by Deloitte USAs energy firms discover and exploit new reserves which require significant amounts of financing, tax authorities have increased their focus on the intra-group financing transactions of such companies. Randy Price, Nadim Rahman and Bill Yohana of Deloitte investigate why the materiality of these transactions may have also increased taxation authority interest in the intra-group financing transactions of energy firms.
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