The recent Altera case in the US Tax Court (on appeal to the Ninth Circuit) raises interesting issues in regard to the much-debated topic of whether customary international tax law (CITL) exists. Altera involved the question whether the cost of employee stock options should be included in the pool of costs that must be shared under a cost sharing agreement. In Xilinx, the Ninth Circuit held under a previous version of the regulations that these costs should not be included because unrelated parties operating at arm’s length would not have agreed to include them. Treasury then amended the regulation to state specifically that “all” costs includes the cost of stock options but did not carve out an exception from the arm’s length standard. In ...
Customary international law is law that “results from a general and consistent practice of states fo...
Tax policy influences the ability of United States businesses to compete internationally. The 1986 T...
The main purpose of transfer pricing provisions is to ensure that associated enterprises, when condu...
The recent Altera case in the US Tax Court (on appeal to the Ninth Circuit) raises interesting issue...
On May 7 the Ninth Circuit decided Xilinx v. Commissioner. By a 2-1 majority, the panel reversed the...
In 1988, the US Treasury Department published a study of inter-company pricing (the \u27White Paper\...
In Altera Corp. v. Commissioner, the United States Tax Court invalidated a 2003 Treasury Regulation ...
A revised and updated version of the 1995 article (Va. Tax Review) on the evolution of US transfer p...
The arm’s length principle has now been for almost eighty years the basis for business income alloca...
One recurring question concerning how legal commands should be formulated in a legal system involves...
The European Court of Justice has confirmed the compatibility of transfer pricing adjustments under ...
The Treasury regulations at issue in Altera Corp. v. Commissioner condition the validity of controll...
This thesis analyzes the evolution of the arm\u27s length standard (ALS) as the key element of the t...
This article addresses some of the fundamental issues behind the current international tax policy de...
This master’s thesis deals with the transfer pricing of intangibles and focuses on the U.S. standard...
Customary international law is law that “results from a general and consistent practice of states fo...
Tax policy influences the ability of United States businesses to compete internationally. The 1986 T...
The main purpose of transfer pricing provisions is to ensure that associated enterprises, when condu...
The recent Altera case in the US Tax Court (on appeal to the Ninth Circuit) raises interesting issue...
On May 7 the Ninth Circuit decided Xilinx v. Commissioner. By a 2-1 majority, the panel reversed the...
In 1988, the US Treasury Department published a study of inter-company pricing (the \u27White Paper\...
In Altera Corp. v. Commissioner, the United States Tax Court invalidated a 2003 Treasury Regulation ...
A revised and updated version of the 1995 article (Va. Tax Review) on the evolution of US transfer p...
The arm’s length principle has now been for almost eighty years the basis for business income alloca...
One recurring question concerning how legal commands should be formulated in a legal system involves...
The European Court of Justice has confirmed the compatibility of transfer pricing adjustments under ...
The Treasury regulations at issue in Altera Corp. v. Commissioner condition the validity of controll...
This thesis analyzes the evolution of the arm\u27s length standard (ALS) as the key element of the t...
This article addresses some of the fundamental issues behind the current international tax policy de...
This master’s thesis deals with the transfer pricing of intangibles and focuses on the U.S. standard...
Customary international law is law that “results from a general and consistent practice of states fo...
Tax policy influences the ability of United States businesses to compete internationally. The 1986 T...
The main purpose of transfer pricing provisions is to ensure that associated enterprises, when condu...