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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

Mar 06, 2013

What Will Be the Impact of Sequestration on Section 1603 of the American Recovery and Reinvestment Act?

The effects of the federal government “sequester” will take many months to figure out completely, but it is becoming increasingly clear that the results will be far-reaching and not necessarily fully anticipated.  For example, Chinese and European manufacturers of solar equipment intended for sale in the United States may be surprised to find out that federal government support for solar projects has taken an unexpected hit.» Read More