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Taxation

Jun 07, 2021

Are U.S. Corporate Tax Hikes Coming? Are Corporate Profit-Shifting to Low-Tax Off-Shore Jurisdictions at Risk?

On May 18, Department of the Treasury Secretary Janet Yellen addressed the U.S. Chamber of Commerce at their Global Forum on Economic Recovery, continuing her pitch to raise corporate taxes and reduce or eliminate the current incentives for sourcing corporate profits off-shore to low-tax countries.» Read More

Apr 08, 2021

BWOB Rewind: Corporate Income Tax, U.S. Economy, and COVID-19 Vaccinations Increase

Yellen calls for minimum global corporate income tax” – Looks to partially offset Biden’s proposed corporate tax increase

With chatter from Senator Mitch McConnell (R – KY) on President Biden’s second stimulus plan, Treasury Secretary Janet Yellen proposed in her virtual remarks to the Chicago Council on Global Affairs, a creative, perhaps aggressive, plan to adopt a global minimum corporate income tax.» Read More

Aug 21, 2018

Manafort’s Trial Reminds Us of Looming OVDP Deadline

With the trial of Paul Manafort in the news, I’ve been thinking of the numerous conversations I have had with clients about properly disclosing foreign financial assets. Among other counts, Paul Manafort is charged with concealing foreign payments and offshore accounts from the U.S.» Read More

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