Trump’s $1.8 billion pact with the IRS has the hallmarks of a collusive settlement, a species of fraud, that could ensnare DOJ personnel involved in designing and administering it, former DC Bar President Philip Lacovara writes.
As part of a Bloomberg Tax Insights series about conflict reshaping tax priorities across the Middle East, KPMG’s Daida Hadzic says that in times of geopolitical instability the ability to decouple work from a fixed location is no longer just an HR perk.
This week, experts analyzed employee retention credit extension requests, the Amex VAT case in France, and more.
Creating a $1.8 billion taxpayer-funded compensation fund in exchange for President Donald Trump dropping his lawsuit against the IRS has government experts trying to make sense of what precedent this creates going forward, Danny Werfel writes.
Congress should provide targeted, temporary relief to households burdened by rising gas prices instead of suspending the federal gas tax, which would worsen a serious transportation funding gap, Andrew Leahey says.
Dr. Glenn DeSouza of Dentons discusses how as fiscal pressures rise and Golden Tax IV rolls out, China is intensifying tax enforcement, placing MNEs under greater scrutiny on transfer pricing, beneficial ownership status, High and New Technology Enterprise status, and R&D super deduction claims.
The OECD has handed tax authorities a robust, treaty-sanctioned framework to attack excessive debt financing, meaning corporate tax directors must ensure every intercompany financial transaction is backed by rigorous analyses, says STI Taxand’s Christos Theophilou.
International tax scrutiny is intensifying, with disputes increasingly focused on intangibles, cross-border structures, and the correct characterization of royalties, says Baker McKenzie’s Antonio Weffer.
A proper transfer pricing policy can have big operational benefits for a company’s functions—such as cash management, supporting net operating losses, and a company’s capital structure, Cherry Bekaert’s Nelson Yates says.
An examination of the IRS’s renewed reliance on the commensurate-with-income standard and the resulting implications for transfer pricing disputes, treaty consistency, and taxpayer risk assessment.
As fast-growing companies expand across borders, failing to align IP ownership with where value is created can trigger significant tax and deal risks.
Companies looking to transfer existing IP from offshore affiliates to US entities, or to place all newly created IP in US affiliates, should know that each choice poses tax and legal challenges.
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