Transfer pricing and MAP: Common traps for the unwary
Transfer-pricing disputes have a tendency to protract themselves over a number of years and discrete stages. For one thing, the uncertainties...
Foreign tax credit: Changing from cash to accrual basis
Aug 4, 2022
On Dec. 28, 2021, Treasury and the IRS issued final foreign tax credit regulations (T.D. 9959) that were officially published...
Customs duty refunds on transfer-pricing adjustments
Jul 14, 2022
Multinational companies (MNCs) often make periodic (including year-end) transfer-price adjustments to address target profit margins and other considerations pursuant to intercompany agreements and...
IRS extends e-filing to more 1040-series amended returns
Jul 5, 2022
IRS extends e-filing to more 1040-series amended returns Taxpayers are now able to file amended returns electronically in more of...
Illegal tax shelter seller finds no shelter in stock forfeiture provision
Jun 29, 2022
A taxpayer’s stock in an S corporation was not subject to a substantial risk of forfeiture due to a forfeiture...
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