On December 16, 2011, the IRS and the Treasury Department issued comprehensive final transfer pricing regulations related to cost sharing arrangements for the development of intangibles ("CSAs").

Tax Alert

On July 27, 2011, the IRS announced further organizational changes intended to improve the agency's administration of the U.S. international tax and transfer pricing rules.

International Tax Alert


In this article, Rocco Femia, Kevin Kenworthy, George Clarke, Kathryn Morrison Sneade, Sat Nam Khalsa and David Blair discuss the IRS's announcement of further organizational changes intended to im


In the wake of the First Circuit's unfortunate decision in Textron, one might be led to believe that documents prepared in order to support the financial accounting treatment of contingent

Tax Alert