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Implications of Disallowed Foreign Deductions for Multinational Enterprises

by Nicholas L. Raby, Susan W. Stanley and Elizabeth A. Sweigart * Although the majority of U.S.-based multinational enterprises make efforts to document and charge for headquarters general and administrative services provided to foreign affiliates under Treas. Reg. § 1.482-9 , not all taxpayers...

Implications of Disallowed Foreign Deductions for Multinational Enterprises

by Nicholas L. Raby, Susan W. Stanley and Elizabeth A. Sweigart * Although the majority of U.S.-based multinational enterprises make efforts to document and charge for headquarters general and administrative services provided to foreign affiliates under Treas. Reg. § 1.482-9 , not all taxpayers...