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Tax litigation in USA

Published by Lexology. Article by: Steptoe & Johnson LLP – Carina C. Federico, J. Walker Johnson and Robert J. Kovacev Competent courts Which courts have jurisdiction to hear tax disputesTax Disputes arise when there is a disagreement between taxpayers and tax authorities regarding the interpretation or application of tax lawsTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More. These disputes may concern various issues such as the accuracy […]

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International Taxation of E-commerce Business Income

Africa, Asia, Europe, International, North America, Oceania, OECD, South America / ATL-Editor

Article by: Dr. Dennis Ndonga (Lecturer, Murdoch University Australia) The rapid growth of cross-border e-commerce has challenged the existing international tax principles that are structured around national boundaries and State sovereignty. Most tax regimes generally assert jurisdiction to tax business income based on the principles of residence-based and source-based taxation. The residence-based system imposes taxes

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Double Tax Treaties: An Introduction

Africa, Asia, Europe, North America, Oceania, OECD, South America / ATL-Editor

Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part of international law. The current DTTs are all based on two models, the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... More and UN model DTTs, which in turn are based on models developed by the League of Nations between 1927 and 1946.

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GlaxoSmithKline vs Canada: Transfer Pricing Case

Canada, Dispute Resolution, Tax Dispute Resolution, TP Case Summaries / Dr Daniel N Erasmus

he GlaxoSmithKline transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More case was a landmark decision in Canadian tax lawTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More. It involved GSK’s Canadian subsidiary and the Canada Revenue Agency (CRA). The dispute centered on the pricing of ranitidine, the active ingredient in the anti-ulcer drug Zantac.

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Xilinx Inc. v. Commissioner of Internal Revenue

International, Postgraduate Programmes in Transfer Pricing, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing, United States / ATL-Editor

The Xilinx Inc. case revolves around whether costs related to employee stock options (ESOs) should be included in the cost-sharing agreement (CSA) between Xilinx Inc. and its subsidiary Xilinx Ireland (XI) under U.S. tax regulationsTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More.

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