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Aug 08, 2018

Surprising Altera Withdrawal for Multinational Companies

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

Aug 02, 2018

What the Altera Case Could Mean for Multinational Companies

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

Jan 20, 2018

IRS Issues Guidance for New Repatriation Tax

Many U.S. owners of foreign companies are surprised to hear that the new repatriation tax not only applies to “repatriated” foreign earnings, but also to foreign earnings that are not repatriated into the U.S.   They are even more surprised to learn that the deemed repatriation tax may be due as early as the 2018 tax season.» Read More

May 09, 2017

IRS Announces Tax Treaties Resulted in Low Withholding Rates to Foreign Individuals and Entities

In the 2017 Statistics of Income Bulletin, the IRS reported that foreign recipients of U.S. source income from treaty countries had an average withholding rate of 13.9% compared to 25.6% for payments made to residents of non-treaty countries.   Absent certain exceptions and/or exemptions, a foreign person, including a foreign entity, is generally subject to tax at a flat 30% rate on U.S.» Read More

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