Monthly Archives: July 2010

OECD publishes revised guidelines on transfer pricing. The OECD has now approved the proposed revisions to Chapters I-III of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Authorities. The revised text results in major changes to the OECD’s authorised … Continue reading →

The Franchise Tax Board (FTB) has announced that, as of July 17, 2010, the total New Jobs Credit generated on personal income tax (PIT) and business entity (BE) tax returns filed/processed is $30,250,693 California has allocated $400 million for this … Continue reading →

Congress passes unemployment insurance bill with estimated tax provisions for large corporations. On July 22, the House of Representatives by a vote of 272-152 approved H.R.4213, the “Unemployment Compensation Extension Act of 2010.” This unemployment insurance extension bill was approved … Continue reading →

Senate takes another stab at passing a small business jobs bill. The Senate leadership appears to be making a determined effort to pass a “new and improved” version of H.R. 5297, the “Small Business Jobs Act.” The latest substitute amendment … Continue reading →

House-passed trade bill would tinker with large corporations’ estimated tax payments. On July 21, the House of Representatives by a vote of 378-43 passed H.R. 4380, the “U.S. Manufacturing Enhancement Act of 2010.” Sec. 3002 of the bill would tinker … Continue reading →

President signs financial reform package with new exclusions from Code Sec. 1256 treatment. Click here for the text of Sec. 1601 of the conference report to accompany H.R. 4173, the “Restoring American Financial Stability Act of 2010.” On July 21, … Continue reading →

Commenters have requested that the Service and Treasury limit the impact of the Foreign Account Tax Compliance Act for many classes of accounts and investments, arguing that such requirements could adversely affect Americans abroad and investment in the United States … Continue reading →

As it has done with respect to certain tangible goods issues, OECD indicated that it is about to embark on an “arduous” project to update the 1995 Transfer Pricing Guidelines relating to intangibles [BNA Daily Tax Report, July 6, 2010, … Continue reading →

Transfer Pricing Case Resolution in Japan Japan, like many countries, has been aggressive in asserting transfer pricing adjustments against both domestic and foreign-based MNEs. Our experience has been that the Competent Authority process of the Japanese tax authority (the National … Continue reading →

“Codification” of the economic substance doctrine—much ado about nothing? Author: By Richard M. Lipton RICHARD M. LIPTON is a partner in the Chicago office of the law firm of Baker & McKenzie LLP, and is a past chair of the … Continue reading →