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By McDermott Will & Emery, Gary C. Karch, Kevin Spencer, Madeline Chiampou Tully, Michael J. Wilder and Robbie H. R. Chen on May 12, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
We recently released the May 2016 issue of “Focus on Tax Strategies and Developments,” which can be viewed in its entirety here or through the links below. The issue includes four articles of interest to taxpayers: Proposed Debt-Equity Regulations Have Dramatic Implications for Corporate Tax Planning and Compliance By Thomas W. Giegerich and Michael J. Wilder On...
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IRS Releases Practice Unit on Residual Profit Split Method
By McDermott Will & Emery and Kristina Novak on May 6, 2016
Posted In IRS Guidance, Transfer Pricing Resource, Uncategorized
On March 7, 2016, the Internal Revenue Service (IRS) released a new International Practice Unit (IPU) on a specific transfer pricing method—the residual profit split method (RPSM). The IPU explains to IRS examiners how to determine if the RPSM is the “best method” under Section 482, and if so, how to apply such method between...
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Tracy Gomes Appointed to Chair of ABA Transfer Pricing Committee
By McDermott Will & Emery on May 5, 2016
Posted In Court Procedure Matters, Transfer Pricing Resource, Uncategorized
We are proud to congratulate our Dallas colleague, Tracy Gomes, McDermott’s chief economist in transfer pricing, upon his appointment as chair of the American Bar Association Transfer Pricing Committee. This position provides the opportunity to propose issues and comments, and to have access to US tax officials in the Internal Revenue Service and Treasury Department...
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BREAKING NEWS: Sales Tax Battle Breaks Out in South Dakota; Quill’s Last Stand?
By McDermott Will & Emery and Stephen P. Kranz on Apr 29, 2016
Posted In Appellate Courts, Trial Courts, Uncategorized
This post is a follow-up to a previous post on McDermott’s Inside SALT blog from April 21, 2016. Introduction On March 22, 2016, South Dakota Governor Dennis Daugaard signed into law Senate Bill 106, which requires any person making more than $100,000 of South Dakota sales or more than 200 separate South Dakota sales transactions to...
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Preparing for a Tsunami of International Tax Disputes
By McDermott Will & Emery and McDermott Will & Emery on Mar 14, 2016
Posted In Alternative Dispute Resolution, IRS Audits, Transfer Pricing Resource, Uncategorized
Recently, we published a Special Report in Tax Notes International, “Preparing for a Tsunami of International Tax Disputes.” The article can be accessed here. While there is near-universal agreement that the number of tax disputes is going to increase, existing international tax dispute resolution processes remain in serious need of improvement. A global consensus must...
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Welcome to McDermott’s Tax Controversy 360 Blog!
By McDermott Will & Emery on Mar 9, 2016
Posted In Uncategorized
McDermott Will & Emery has a leading tax controversy practice with lawyers representing clients on all aspects of federal, state and local, and international tax controversy matters, including Internal Revenue Service audits and appeals, competent authority matters and trial and appellate litigation. We regularly represent some of the world’s largest corporations on complex US, state...
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