Second US trial in Medtronic v. Commissioner may point to unspecified TP method Mark Martin and Thomas Bettge of KPMG in the US discuss the second US Tax Court trial in Medtronic v. Commissioner and consider how the case may ultimately be resolved. By Mark Martin & Thomas Bettge September 24 2021
US Tax Court finds limits to treaty-based double tax relief By Mark Martin & Thomas Bettge September 14 2021
IRS memo raises issues for post-Altera stock-based compensation true-ups By Mark Martin & Thomas Bettge September 06 2021
US Tax Court holds UK treaty does not protect right to deductions By Mark Martin & Thomas Bettge March 04 2021
OECD GloBE consultation focuses on details but overall design remains hazy By Mark Martin & Thomas Bettge January 06 2020
Remarkably unremarkable results for APAs in the midst of COVID-19 By Mark Martin & Thomas Bettge June 02 2021
US: New horizons for dispute resolution under pillar one’s Amount A By Mark Martin & Thomas Bettge November 19 2020
US: Tax Court to decide on foreign taxpayer’s right to deductions in Adams Challenge By Mark Martin & Thomas Bettge August 10 2020
New IRS policy restricts telescoping for APA and competent authority resolutions By Mark Martin & Thomas Bettge January 26 2021
US: Thinking through secondary transfer pricing adjustments By Mark Martin & Thomas Bettge October 29 2020
US: Foreign-controlled CFCs - assessing the regulations for dealing with downward attri... By Mike Knobler & William Skinner October 28 2020
A look at tax liability insurance in the US: Practical considerations By Dean Andrews October 21 2020
Section 163(j): A closer look at inbound financing developments in the US By Mike Knobler & William Skinner September 30 2020
Transfer pricing remains crucial as IRS CAP programme opens for 2021 By Mark Martin & Thomas Bettge September 29 2020
