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Texas District Court on Anti-Inversion Legislation – One Down but Not Out

Texas District Court on Anti-Inversion Legislation – One Down but Not Out

The final months of the Obama administration saw the hurried adoption of temporary regulations in an attempt to extend its tax policy into the current administration.  However, reliance on temporary regulations that are adopted without a public comment period may have been misguided.  In October, a U.S. District Court struck down a provision under temporary anti-inversion regulations for violating the required notice and comment period under the Administrative Procedure Act.  Beate Erwin and Sheryl Shah explain the web of issues involved in the decision.

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Transfer Pricing Litigation from A to Z

A number of transfer pricing cases, many with potentially significant precedent value and tax provision consequences, are either at trial or proceeding to trial. Michael Peggs and Cheryl Magat comment on two of the major cases on the Tax Court Docket, Altera and Zimmer. Those who think arm’s length means “do what others do” will be surprised.

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