The International Tax Journal

The International Tax Journal articles

381 total articles

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Recently added articles from The International Tax Journal:

Tax Court Rejects IRS' Code Sec. 367(d) Argument
November 1, 2017 ... A domestic corporation that transfers to a foreign subsidiary intangible property within the meaning of Code Sec. 936(h)(3)(B) in an otherwise tax-free transfer is subject to taxation under Code Sec. 367(d) on a contingent sale basis. Code Sec....

Select Cross-Border Tax Issues in Reverse Morris Trust Transactions
November 1, 2017 ... I. Introduction The tax press in recent years has focused considerable attention on certain types of transactions, with so-called inversion transactions high on that list. In addition, related party financings subject to new Code Sec. 385...

Are Non-U.S. Pharmas "Paid" to Stay Offshore?
November 1, 2017 ... The United States has one of the highest nominal corporate tax rates in the world: a maximum 35% U.S. federal corporate income tax rate, with state and local income taxes often pushing this above the 40% mark. By comparison, a country such as...

Structuring Options for Individuals and the Unwanted Foreign Holding Company
November 1, 2017 ... Many taxpayers, particularly individuals, are in the habit of creating structures and making investments without consulting their tax advisors. This is seldom an ideal course of action, but it can be particularly dangerous in the foreign area,...

Intangible Revenues Assigned to the Developer and Not to the Funder Lacking "Development Monitoring Staff": OECD Transfer Pricing Anti-Abuse Rule Clashes with Economics of Contracts
November 1, 2017 ... 1. OECD TPG After 2015 BEPS: The Issue of the Intangible's Funder Lacking Ability to Monitor Intangible's Performer With the 2015 BEPS changes to the OECD's Transfer Pricing Guidelines (TPG) chapter VI on intangibles, the entitlement to...