Tax Law

Recent Posts

From the NYT: Lessons for International Tax from Oregon's Role as Sales/Use Tax Haven
Posted on 14 Apr 2014 by Allison Christians

Today's [April 13, 2014] NYT has an article entitled " Buyers Find Tax Break on Art: Let it Hang Awhile in Oregon ." The artful dodge is accomplished via simple arbitrage between a source, an intermediary, and a residence jurisdiction, so... Read More

Effectively Integrating Tax and Transfer Pricing Requirements with Enterprise Resource Planning
Posted on 12 Dec 2013 by LexisNexis Tax Law Community Staff

by David A. Nickson, Andrew J. Hwang and Elizabeth A. Sweigart * As multinational enterprises continue to expand through acquisition and organic growth, the need for accurate and timely reporting of operational and financial data has never been more... Read More

Canadian AML Law
Posted on 11 Nov 2013 by LexisNexis Tax Law Community Staff

by Jeffrey R. Simser and Robert G. Kroeker * Introduction ... The AML regime in any country is apt to be vexing and complex. Canada's is no exception.. Overview of AML Law in Canada Canada is a country of immense size, bordered by the... Read More

Tax Effects of Sun Capital Partners III, LP for Non-U.S. Private Equity Funds
Posted on 17 Dec 2013 by Rufus v. Rhoades & Alexey Manasuev

In Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund [724 F.3d 129 (1st Cir. 2013)], the First Circuit held that one of two private equity funds (the two funds were Sun Capital Fund III and Sun Capital Fund IV... Read More

Transfer Pricing and Foreign Tax Credit Analysis for Inter-Branch Transactions
Posted on 1 Apr 2014 by LexisNexis Tax Law Community Staff

by Dale Bond, Elizabeth Sweigart and Alan Fischl * Conventionally, the structuring and pricing of transactions between US taxpayers and their related parties — or transfer pricing — has been considered the realm of large, multinational... Read More

Caterpillar v. Comm'r and the Rule of Law in International Tax
Posted on 6 Aug 2013 by Allison Christians

James P. Fuller has an interesting summary of the recently-filed Caterpillar case in his latest U.S. Tax Review [ gated ], in which he laments the competent authority breakdown and argues that the case would have been better off going to treaty-based... Read More

Intercompany Agreements for U.S.-Based Multinational Enterprises
Posted on 30 Dec 2014 by LexisNexis Tax Law Community Staff

On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its final guidance on transfer pricing documentation and country-by-country (CbC) reporting. Developed as a replacement for the existing Chapter V (Documentation... Read More

Transfer Pricing and International Taxation: A Continuing Problem for Taxing Authorities
Posted on 17 Nov 2014 by LexisNexis Tax Law Community Staff

by Mary Riley * It is a general maxim that taxpayers want to minimize their tax liability to the greatest extent possible. However, taxpayers who overzealously pursue this aim risk crossing the line separating permissible tax avoidance from impermissible... Read More

Virtual Currency Regulatory Developments
Posted on 16 Jun 2014 by LexisNexis Tax Law Community Staff

By Prof. William H. Byrnes IV and Dr. Robert J. Munro * Editor's Note : The following is an excerpt from the e-book only title Money Laundering, Asset Forfeiture, and Recovery and Compliance - A Global Guide , by William Byrnes and Robert Munro... Read More

Filing Compliance Procedures Challenge U.S. Taxpayers Residing Overseas
Posted on 22 Oct 2014 by Rufus v. Rhoades & Alexey Manasuev

Generally, [the 2012 Offshore Voluntary Disclosure Program] OVDP is designed for those delinquent U.S. taxpayers who have been holding financial assets overseas, have not been disclosing such assets to the U.S. government, have not been reporting... Read More