On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion. On December 14, 2015, Coca-Cola petitioned the U.S. Tax Court to overturn the adjustments. This… – Continue reading
On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based… – Continue reading
Stymied in their efforts to fully repeal the Affordable Care Act (ACA), Republican leaders in Congress continue their efforts to undermine the law by starving it of funding. Today, the Senate Finance Committee will consider legislation that would repeal some of the tax changes enacted to pay for the ACA…. – Continue reading
TP Week As a result of Brazil’s unique policy to prevent erosion of the tax base, companies often face double taxation. The pending case before the US Tax Court (Docket 5816-13), 3M Co. et al. v. Commissioner, brings this issue into the spotlight. In this case the US Internal Revenue… – Continue reading
Foreign profits sit on sidelines as companies seek tax reform. WASHINGTON — They are all companies that call Minnesota home: Medtronic, 3M, St. Jude Medical, General Mills and Ecolab. But they also all hold 90 percent or more of their cash outside the United States. Amid a growing national political… – Continue reading
