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Obama Wants International Tax Reform

President Obama introduced his plan to crack down on off-shore tax havens and remove tax incentives available to multinational corporations. Martin DiGiovine explores the implications.

Update: Transfer Pricing Developments

Cost sharing arrangements (“CSA’s”) are agreements among related parties to share the costs of developing intangible property (trademarks, know-how, patents, or similar items) in proportion to their shares of reasonably anticipated benefits from the use of the intangible.  As with all related party transactions, the rules require “arm’s length pricing”- what unrelated parties would pay under the same circumstances.  Mary Richter provides insight.

Introduction of Foreign Dividend Exclusion System

The Japanese ruling coalitions and governmental agencies have agreed and released an outline of the 2009 tax reform proposals on December 12, 2008. Under

International Tax Update

On December 15, 2008, the Fifth Protocol to the US- Canadian tax treaty entered into force. Provisions of the protocol with Canada, which amends the existing

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What is New in Transfer Pricing- Uncommon Sense

The IRS’s compliance directives (and increased numbers of tax audits) are causing companies to disclose more information than ever on tax returns.

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