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IRS discusses application of residual profit-split method to outbound IP transactions

IRS discusses application of residual profit-split method to outbound IP transactions

Residual Profit Split Method – Outbound (ISO/PUO/P_1.7_04(2014)) (Mar. 7, 2016). IRS has released a new international practice unit (IPU) illustrating the application of a specific transfer pricing method, the residual profit-split method (RPSM), to a transaction where a U.S. parent corporation (USP) licenses certain intangible property (IP) to its controlled foreign corporation (CFC) in exchange […]

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Altera again petitions Tax Court to invalidate section 482 stock-based compensation rules

Altera again petitions Tax Court to invalidate section 482 stock-based compensation rules

Altera Corp. v. Commissioner, TC Docket No. 31538-15 (petition filed on Dec. 18, 2015) . Altera Corp. has filed a new petition with the Tax Court to challenge IRS again on whether related parties entering into qualified cost sharing arrangements (CSAs) are required to share stock-based compensation (SBC) costs under Code Sec. 482. The Tax […]

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IRS issues guidance to its examiners on auditing transactions under sections 367(b) and 482

IRS issues guidance to its examiners on auditing transactions under sections 367(b) and 482

IRS has released two international practice units (IPUs) providing an overview of foreign-to-foreign transactions under Code Sec. 367(b) and transfer pricing under Code Sec. 482. IPUs generally identify strategic areas of importance to IRS and can provide insights as to how IRS examiners may audit a particular issue or transaction. Background—foreign-to-foreign transactions under 367(b). With […]

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Tax Court strikes down cost sharing reg’s requirement to share stock-based compensation costs

Tax Court strikes down cost sharing reg’s requirement to share stock-based compensation costs

Altera Corporation and Subsidiaries, (2015) 145 TC No. 3 The Tax Court has held invalid the Code Sec. 482 cost-sharing regs that require controlled entities entering into qualified cost-sharing agreements (QCSAs) to share stock-based compensation (SBC) costs.  Click here for the Opinion of the Court. Background on arm’s-length standard. Code Sec. 482 authorizes IRS to […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney