United States Tax Court Invalidated Treasury Regulation § 1.482-7(d)(2)

September 14, 2015

On July 17, 2015, the US Tax Court (en banc) ruled in favor of the taxpayer in Altera Corporation v. Commissioner, 1 holding that Treas. Reg. 1.482-7(d)(2), which was issued in 2003 requiring participants in qualified cost-sharing arrangements (“QCSAs”) to share stock-based compensation costs to achieve an arm’s-length result, was arbitrary and capricious and therefore invalid. Altera US, the parent company of an affiliated group …


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Lower copper prices to hit Zambia revenue receipts -official

September 14, 2015

A slide in global copper prices has put pressure on Africa’s second biggest producer of the metal, with export earnings depressed despite the kwacha’s 55 percent fall against the dollar this year. The finance minister cut his original revenue target by 2.12 billion kwacha in June, and on Wednesday Zambia Revenue Authority (ZRA) commissioner general Berlin Msiska suggested the shortfall could be bigger. “I think …


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Boustany–Neal Innovation Box: Complex and Unsound Policy

September 14, 2015

Talk in Congress of establishing an innovation box (also called a patent box) has increased in recent days. An innovation box would lower tax on income earned from certain types of intellectual property (IP). Innovation boxes exist in several countries around the world, including many major U.S. trading partners. The purpose of the boxes is to lower the tax rate on certain types of highly …


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Further developments in the BEPS project

September 14, 2015

A number of further publications have been released this quarter as part of the Organisation for Economic Co-Operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) project. These include: The 8 June 2015 publication by the OECD of a package of measures relating to “country- by-country reporting” (relevant to Action 13 of the BEPS project). This package includes model domestic legislation and international agreements …


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Vodafone transfer–pricing case explained

October 15, 2015

Vodafone transfer-pricing case explained Vodafone claimed the sale in question was not an international transaction and thus should not be subject to transfer-pricing rules. Even as the tribunal considered the company's plea, the I-T department issued a demand for tax amounting to Rs 3,700 … Read more on Business Standard Vodafone Secures Indian Transfer Pricing Ruling Accepting Vodafone's argument, the Bombay High Court set aside …


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