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Back To The Future Medtronic And The Future Of Transfer Pricing
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Book Synopsis Back to the Future? Medtronic and the Future of Transfer Pricing by : R.S. Avi-Yonah
Download or read book Back to the Future? Medtronic and the Future of Transfer Pricing written by R.S. Avi-Yonah and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The recent decision of the Tax Court in Medtronic is a milestone. It is the first full-fledged application of the 1995 transfer pricing regulations to reach a final court determination. Recent transfer pricing cases such as Veritas, Xilinx and Altera focused on cost sharing, which is an important technique to shift profits out of the United States but does not directly implicate comparability under the arm's-length standard (ALS). Prior to Medtronic, transfer pricing cases involving comparability were either based on pre-1995 regulations (e.g., Sundstrand and Seagfate) or were settled without a final court opinion (e.g., Glaxo). Thus, Medtronic is an important indication of where transfer pricing stands now. What is remarkable about Medtronic, however, is how familiar it seems to anyone who knows about transfer pricing case law prior to 1995. Both the facts and the outcome are quite similar to a series of cases involving Puerto Rico affiliates of U.S. multinationals from the 1980s. But these cases led Congress to amend Code Sec. 482 for the only time in its long history to add the "commensurate with income" (super-royalty) standard, which was supposed to prevent precisely this kind of outcome. How could the result be so familiar? This article first goes back to the historical cases preceding the change in Code Sec. 482, then discusses Medtronic, and finally asks what this means for the future of transfer pricing in the age of base erosion and profit shifting (BEPS).
Book Synopsis 'Medtronic V. Commissioner' : a Taxpayer Win on Transfer Pricing, Commensurate with Income, and Section 367 Issues by : M.R. Martin
Download or read book 'Medtronic V. Commissioner' : a Taxpayer Win on Transfer Pricing, Commensurate with Income, and Section 367 Issues written by M.R. Martin and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Commentary on the opinion of 9 June 2016, released by the U.S. Tax Court in Medtronic, Inc. and Consolidated Subsidiaries v. Commissioner case. The Internal Revenue Service had taken issue with the transfer pricing of transactions between Medtronic, Inc. and its Puerto Rican manufacturing arm under Section 482 of the Internal Revenue Code. Finding the IRS's application of the comparable profits method (CPM) to the transactions arbitrary and capricious, and taking issue as well with the taxpayer's comparable uncontrolled transaction (CUT) methodology, the court ultimately made its own decision as to arm's-length pricing, arriving at new allocations by making adjustments to the taxpayer's original CUT approach.
Book Synopsis Transfer Pricing Developments Around the World 2022 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2022 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries’ legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments. Transfer Pricing Developments in the European Union. Transfer Pricing Developments in the United States. Transfer Pricing Developments in Developing Countries and Emerging Economies. Recent Developments on Transfer Pricing in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.
Book Synopsis Should a Bad CUT Prevail in the Medtronic Transfer Pricing Appeal?. by : D.G. Chamberlain
Download or read book Should a Bad CUT Prevail in the Medtronic Transfer Pricing Appeal?. written by D.G. Chamberlain and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: At a time when transfer pricing for intangible property is hotter than ever on the international stage, oral arguments have just been heard in the appeal of one of the key U.S. cases decided in recent years. The Internal Revenue Service (IRS) has appealed an adverse decision by the Tax Court in its dispute with Medtronic, Inc.
Book Synopsis Transfer Pricing Developments Around the World 2020 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2020 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2020-09-28 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Book Synopsis How the Tax Court Can Account for Risk in Medtronic Transfer Pricing by : D.G. Chamberlain
Download or read book How the Tax Court Can Account for Risk in Medtronic Transfer Pricing written by D.G. Chamberlain and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the author explores how the Tax Court, on remand in Medtronic, can address the challenge of determining arm's-length transfer prices when one of the related parties bears substantial risk but owns no valuable intangible property.
Book Synopsis The future of transfer pricing by : International Fiscal Association. Congress
Download or read book The future of transfer pricing written by International Fiscal Association. Congress and published by . This book was released on 2017 with total page 900 pages. Available in PDF, EPUB and Kindle. Book excerpt: 102B: Cahiers de droit fiscal international: The IFA Cahiers' are released annually by Sdu on behalf of the IFA (International Fiscal Association). These "Cahiers" contain a wealth of domestic and international material in dealing with the Subjects to be discussed at the following Congress. They comprise IFA Branch Reports together with a General Report and an EU Report on each of the two Subjects selected for the Congress of that year. Subject Subject for 2017, 102B is?The future of transfer pricing?. See also Section 102-A. Members of the IFA can contact the IFA to obtain a discount code to fill in.
Book Synopsis Fraud, Waste, and Abuse in the Medicare Pacemaker Industry by : United States. Congress. Senate. Special Committee on Aging
Download or read book Fraud, Waste, and Abuse in the Medicare Pacemaker Industry written by United States. Congress. Senate. Special Committee on Aging and published by . This book was released on 1983 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Converging Technologies for Improving Human Performance by : Mihail C. Roco
Download or read book Converging Technologies for Improving Human Performance written by Mihail C. Roco and published by Springer Science & Business Media. This book was released on 2013-04-17 with total page 477 pages. Available in PDF, EPUB and Kindle. Book excerpt: M. C. Roco and W.S. Bainbridge In the early decades of the 21st century, concentrated efforts can unify science based on the unity of nature, thereby advancing the combination of nanotechnology, biotechnology, information technology, and new technologies based in cognitive science. With proper attention to ethical issues and societal needs, converging in human abilities, societal technologies could achieve a tremendous improvement outcomes, the nation's productivity, and the quality of life. This is a broad, cross cutting, emerging and timely opportunity of interest to individuals, society and humanity in the long term. The phrase "convergent technologies" refers to the synergistic combination of four major "NBIC" (nano-bio-info-cogno) provinces of science and technology, each of which is currently progressing at a rapid rate: (a) nanoscience and nanotechnology; (b) biotechnology and biomedicine, including genetic engineering; (c) information technology, including advanced computing and communications; (d) cognitive science, including cognitive neuroscience. Timely and Broad Opportunity. Convergence of diverse technologies is based on material unity at the nanoscale and on technology integration from that scale.
Book Synopsis Schwarz on Tax Treaties by : Jonathan Schwarz
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Book Synopsis The Business of Healthcare Innovation by : Lawton R. Burns
Download or read book The Business of Healthcare Innovation written by Lawton R. Burns and published by Cambridge University Press. This book was released on 2005-08-25 with total page 400 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first wide-ranging analysis of business trends in the manufacturing segment of the health care industry.
Download or read book Popular Science written by and published by . This book was released on 2003-12 with total page 190 pages. Available in PDF, EPUB and Kindle. Book excerpt: Popular Science gives our readers the information and tools to improve their technology and their world. The core belief that Popular Science and our readers share: The future is going to be better, and science and technology are the driving forces that will help make it better.
Book Synopsis Hunger, Nutrition, Older Americans by : United States. Congress. Senate. Special Committee on Aging
Download or read book Hunger, Nutrition, Older Americans written by United States. Congress. Senate. Special Committee on Aging and published by . This book was released on 1982 with total page 750 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Artificial Intelligence in Healthcare by : Adam Bohr
Download or read book Artificial Intelligence in Healthcare written by Adam Bohr and published by Academic Press. This book was released on 2020-06-21 with total page 385 pages. Available in PDF, EPUB and Kindle. Book excerpt: Artificial Intelligence (AI) in Healthcare is more than a comprehensive introduction to artificial intelligence as a tool in the generation and analysis of healthcare data. The book is split into two sections where the first section describes the current healthcare challenges and the rise of AI in this arena. The ten following chapters are written by specialists in each area, covering the whole healthcare ecosystem. First, the AI applications in drug design and drug development are presented followed by its applications in the field of cancer diagnostics, treatment and medical imaging. Subsequently, the application of AI in medical devices and surgery are covered as well as remote patient monitoring. Finally, the book dives into the topics of security, privacy, information sharing, health insurances and legal aspects of AI in healthcare. Highlights different data techniques in healthcare data analysis, including machine learning and data mining Illustrates different applications and challenges across the design, implementation and management of intelligent systems and healthcare data networks Includes applications and case studies across all areas of AI in healthcare data
Book Synopsis Transfer Pricing and Developing Economies by : Joel Cooper
Download or read book Transfer Pricing and Developing Economies written by Joel Cooper and published by World Bank Publications. This book was released on 2017-01-05 with total page 275 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
Book Synopsis No More Laughing at the Deaf Boy by : Geoffrey Ball
Download or read book No More Laughing at the Deaf Boy written by Geoffrey Ball and published by Haymon Verlag. This book was released on 2012-06-29 with total page 334 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hearing loss affects countless millions of people, yet few sufferers even seek help, let alone try to find a cure. This is the story of a man who took on that daunting task and ultimately invented the world's most successful middle ear implant. Geoffrey Ball's adventure in technology began in the legendary Silicon Valley of California, the birthplace of so many innovations that have transformed our world, and ultimately led him to the mountains of Austria, where he now lives and continues his work. Ball's deafness was diagnosed early, but even as a child he knew that sign language and conventional hearing aids were not the answer. Despite his proficiency in lipreading, he wanted more - a better fix. Meanwhile, Ball never let his disability stand in his way. He became a kind of modern Renaissance man with interests that ranged from literature to sports to music, all coupled with an undeniable talent for entrepreneurship and invention. The author introduces us to family and friends, surfing buddies and lab rats, business partners and fellow inventors, computer and Internet legends, a brilliant, larger-than-life mentor who gave him his start, and the woman who ultimately saved his brainchild. He intersperses insights into technology, funding and business acumen with personal, often humorous anecdotes and fascinating accounts of successes, failures and near misses along the way. Today, every hour, somewhere in the world, one of his ground- breaking devices improves the quality of life of a hearing-impaired person. No one is laughing at the deaf boy now, and we haven't heard the last of Geoffrey Ball.
Book Synopsis Corporate Profit Shifting by : Dorian L. Peters
Download or read book Corporate Profit Shifting written by Dorian L. Peters and published by . This book was released on 2015 with total page 171 pages. Available in PDF, EPUB and Kindle. Book excerpt: Congress and the Obama Administration have expressed interest in addressing multinational corporations' ability to shift profits into low- and no-tax countries with little corresponding change in business operations. Several factors appear to be driving this interest. Economists have estimated that profit shifting results in significant tax revenue losses annually, implying that reducing the practice could help address deficit and debt concerns. Profit shifting and base erosion are also believed to distort the allocation of capital as investment decisions are overly influenced by taxes. Fairness concerns have also been raised. If multinational corporations can avoid or reduce their taxes, other taxpayers (including domestically focused businesses and individuals) may perceive the tax system as unfair. At the same time, policymakers are also concerned that American corporations could be unintentionally harmed if careful consideration is not given to the proper way to reduce profit shifting. This book is intended to assist Congress as it considers what, if any, action to curb profit shifting. This book discusses the methods used for shifting profits only to the extent that it is necessary for interpreting the data or discussing policy options. In addition, this book addresses tax havens; basic concepts and policy issues of U.S. international corporate taxation; and reforms of U.S. international taxation.
