In a surprising twist of events, the Ninth Circuit Court of Appeals withdrew their recent transfer pricing decision against Altera Corp.1 The Ninth Circuit previously upheld Treasury regulations regarding the criteria for a cost-sharing arrangement to be considered qualified and thus avoid an IRS adjustment. » Read More
The IRS scored a major victory in the recent transfer pricing case, Altera Corp. & Subsidiaries v. Commissioner, No. 16-70496 (9th Cir. 2018). The issue before the Ninth Circuit was the validity of transfer pricing regulations that require related companies to allocate expenses that unrelated parties do not share when dealing at arm’s length.» Read More
The below post is written by guest author Elena Bassan, an attorney with the Italian law firm Studio Bassan.
Today, we comment on a ruling of the Supreme Court of Cassazione (no. 3692 of 15 February 2018) concerning a product reported to be allegedly defective due to its content of heavy metals (nickel).» Read More
Way back on August 17, 2017 (seems like a lifetime ago), we brought you information regarding the European General Data Protection Regulation (“GDPR”) and its impact on those doing business in the EU*.
And now, guess what–the GDPR goes live on May 25, a week from today. » Read More
UNITED STATES BUSINESS ENTITIES OWNING BRAZILIAN CORPORATIONS AND LIMITED LIABILITY COMPANIES MUST CAUSE THEIR BRAZILIAN SUBSIDIARIES TO PERFORM SHAREHOLDERS/ QUOTAHOLDERS ANNUAL MEETING BY THE END OF APRIL
All Brazilian Corporations and Limited Liability Companies must hold a Shareholders Annual Meeting (AGO) or a Quotaholders Meeting (RQ), respectively, for discussion and approval of the four items noted below as required by Article 132 of Brazil Federal Law 6.404/76 and Article 1.078 of the Brazilian Civil Code; those meetings must be held within the four months following the end of the previous fiscal year (April 30 for most companies):
• management’s report, exam, discuss and vote the company financial statements;
• approval of the destination of the net profit and distribution of dividends;
• appointment of directors and the members of the board of auditors, if the case may be; and
• approval of the inflation adjustment of the capital of the company (art.» Read More