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10.10.2025

Firm Publication

Perrigo Opinion Upholds Economic Substance of Intercompany Assignment of Contract Rights

Tax Alert

08.19.2025

External Publication

Exam: Continued Emphasis on Transfer Pricing Issues in Examinations and How to Resolve Transfer Pricing Disputes

06.13.2025

Firm Publication

Tax Court Issues Split Ruling in Facebook

Tax Alert

05.14.2025

Firm Publication

Applying Transfer Pricing Principles to Determine Customs Value on Which Tariffs Are Imposed

Tax Alert

04.10.2025

Firm Publication

Using the First Sale Rule to Reduce Tariffs

International and Tax Alert

04.03.2025

Firm Publication

Tariff Increases Create Transfer Pricing Challenges for U.S. Importers

Tax Alert

02.13.2025

Firm Publication

IRS Clarifies Position on the Periodic Adjustment Rules

Tax Alert

12.12.2024

Firm Publication

Treasury and IRS Release Long-Awaited Proposed Regulations on Previously Taxed Earnings and Profits

Tax Alert

12.12.2024

Firm Publication

MAP and APA Proceedings Remain a Successful Option for U.S. Taxpayers Operating in an Increasingly Complex World

Tax Alert

11.04.2024

Firm Publication

IRS and Treasury Announce Section 482 Guidance Project for Application of Simplified and Streamlined Approach to Baseline Distribution Activities (Amount B of Pillar One)

Tax Alert

09.16.2020

Firm Publication

Latest BEAT Regulations Finalize Rules for Waiving Deductions

Tax Alert

07.20.2020

Firm Publication

Final FDII and GILTI Regulations Significantly Relax Documentation Requirements

Tax Alert

10.10.2019

Firm Publication

Brave New Taxing Right: OECD Releases Pillar One Consultation Document

Tax Alert

06.24.2019

Firm Publication

Treasury Releases New Regulations Providing Guidance Under GILTI and Participation Exemption

Tax Alert

06.17.2019

External Publication

Interest Deductibility: The Implementation of BEPS Action 4 General Report for International Fiscal Association 2019 Congress

04.30.2019

Firm Publication

2019 Tax Policy Forecast Survey Report

03.07.2019

Firm Publication

Proposed Regulations Provide Guidance on FDII and GILTI Deductions

Tax Alert

02.01.2019

External Publication

Transfer Pricing: Document Requests and Summons Enforcement, No. 6925

12.20.2018

Firm Publication

BEAT Proposed Regulations Provide Important Guidance

Tax Alert

12.12.2018

Firm Publication

IRS Provides Guidance on Updated Voluntary Disclosure Practice Following the Recent Closing of the Offshore Voluntary Disclosure Program

Tax Alert

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publications

Perrigo Opinion Upholds Economic Substance of Intercompany Assignment of Contract Rights

Exam: Continued Emphasis on Transfer Pricing Issues in Examinations and How to Resolve Transfer Pricing Disputes

Tax Court Issues Split Ruling in Facebook

Applying Transfer Pricing Principles to Determine Customs Value on Which Tariffs Are Imposed

Using the First Sale Rule to Reduce Tariffs

Tariff Increases Create Transfer Pricing Challenges for U.S. Importers

IRS Clarifies Position on the Periodic Adjustment Rules

Treasury and IRS Release Long-Awaited Proposed Regulations on Previously Taxed Earnings and Profits

MAP and APA Proceedings Remain a Successful Option for U.S. Taxpayers Operating in an Increasingly Complex World

IRS and Treasury Announce Section 482 Guidance Project for Application of Simplified and Streamlined Approach to Baseline Distribution Activities (Amount B of Pillar One)

Latest BEAT Regulations Finalize Rules for Waiving Deductions

Final FDII and GILTI Regulations Significantly Relax Documentation Requirements

Brave New Taxing Right: OECD Releases Pillar One Consultation Document

Treasury Releases New Regulations Providing Guidance Under GILTI and Participation Exemption

Interest Deductibility: The Implementation of BEPS Action 4 General Report for International Fiscal Association 2019 Congress

2019 Tax Policy Forecast Survey Report

Proposed Regulations Provide Guidance on FDII and GILTI Deductions

Transfer Pricing: Document Requests and Summons Enforcement, No. 6925

BEAT Proposed Regulations Provide Important Guidance

IRS Provides Guidance on Updated Voluntary Disclosure Practice Following the Recent Closing of the Offshore Voluntary Disclosure Program

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