Can I Charge An Interest Rate On Intercompany Loans That Is Different From The Safe Harbor Rate?
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How Can I Replace One Transfer Pricing System With Another System Without Raising Red Flags?
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The Field Audit Team Has Proposed A Transfer Pricing Adjustment. What Are My Options To Fight The Adjustments?
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Under What Circumstances Will The Sale Of Intellectual Property ("IP") By A Controlled Foreign Corporation ("CFC") Give...
Asked in California, United States
Are There Any Transaction Structures That Can Be Utilized By A US Corporation To Repatriate Low-taxed Offshore Cash In The Context Of The...
Asked in California, United States
Does Liability Assumption Reduce The Amount Of Gain Recognized Under Section 356(a)(1) In The Same Manner As It Does Under Section 301?
Asked in California, United States
What Must Be Done To Obtain Hedging Treatment For US Federal Income Tax Purposes, And What Is The Benefit Of Obtaining Hedging Treatment?
Asked in California, United States
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If I Have Bank Accounts Or Other Property Outside The U.S., What U.S. Reporting Is Required To Be Fully Compliant With All U.S. Laws?
Asked in California, United States
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