International Tax & Transfer Pricing
European Commission Appeals Apple’s Major “State Aid” Tax Victory
Earlier this summer, Apple won a $15 billion State Aid case related to its Irish operations. This decision was rendered by the EU’s lower court. In late September, the European Commission…
Read MoreSupreme Court Denies Review of Tax Breaks for Big Tech Companies in Altera but the Controversy Continues
The Supreme Court denied a petition of certiorari in Altera v. Commissioner on June 22, 2020, a closely followed case from the Ninth Circuit concerning the validity of a 2003…
Read MoreThe Future of International Taxation: BEPS 2.0, DSTs, or What?
Even as regulatory guidance is still being issued by the U.S. Treasury, nearly 2-1/2 years after the enactment of sweeping changes to the international taxation of U.S.-based multinational enterprises (MNEs),…
Read MoreTreasury Releases Final Section 385 Regulations without Substantive Changes to the 2016 Proposed Regulations.
Internal Revenue Code (IRC) Section (§) 385(a) provides that the Secretary of the Treasury is authorized to prescribe regulations as may be necessary or appropriate to determine whether an interest…
Read MoreCompanies Continue to Evaluate APB 23 Benefits After Tax Reform; Impact of COVID-19 Related Repatriations on the Indefinite Reinvestment Assertion
The general comprehensive rule for providing deferred taxes on book-tax basis differences under ASC 740-10 requires companies to record a deferred tax liability (DTL) for any GAAP outside basis in…
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