Insights & Resources

IRS signs competent authority arrangements ensuring that taxpayers will maintain favorable treatment in income tax treaties with Denmark, Luxembourg, Malta & Mexico.

Recent news about transfer pricing includes Brazilian transfer pricing rules, migration of intangible assets and IRS guidance for financial transactions.

Real Estate Investment Trusts (REITs) are subject to a number of transfer pricing rules and, when applicable, to onerous penalties. Learn about the requirements.

The IRS issued proposed regulations on the application of the federal Superfund Tax that address a number of issues surrounding the imposition of the tax.

Skechers was found to owe more than $1M in taxes after losing a transfer pricing dispute that involved a royalty expense taken as a tax deduction.

In the March 6 Internal Revenue Bulletin the IRS issued a statement on export tax for oil spills. Find out more about this notice and how taxpayers are affected.

In a recent decision, the First District Court of Appeals in Illinois held that book-out transactions are transfers of ownership of fuel and are subject to tax.

U.S. investors run a risk of diminishing returns if they do not understand how PFIC rules apply to foreign investments. Learn about the tax consequences.

A number of states have updated their motor fuel tax rates and related fees effective in the first quarter of 2023.

Increased IRS funding may mean greater attention from IRS auditors to transfer pricing, which has been the target of political & public concerns over tax avoidance.

The IRS has issued guidance on new sustainable aviation fuel tax credits that take effect on January 1, 2023. The guidance, Notice 2023-06, includes the following:

Find out why U.S. multinationals with Australian operations can potentially be subject to double taxation based on Australia’s “hybrid mismatch rules.”