June 2, 2021
Blog 2 of 4: This is the second in a series of blogs that attempts…
17
02 '16
US multi-nationals have long enjoyed the simplicity and tax certainty afforded by Cost Sharing Arrangements (CSA). In a CSA, participants share in the development of valuable intangibles in exchange for the right to exploit the resulting intangible. The cost of the development activity is allocated to the participants based on each participant’s expected benefit. (To…
05
02 '16
Our research suggests it will, but not for a few more years.
02
02 '16
Oil & Gas Price Outlook February 2016 A wild ride to expected values! In our January blog, we showed that futures markets predicted a one-standard deviation range (68% probability) for oil prices was expected to be approximately $33 – $39 per barrel as of month end. The day after we published, oil prices began falling…
05
01 '16
Happy New Year! Oil & Gas Price Outlook January 2016 After enduring a 32% drop in crude oil prices and a 35% drop in natural gas prices in 2015, this next year has to improve… doesn’t it?? While futures markets aren’t a crystal ball, with a little bit of statistical analysis, they can tell us…
04
01 '16
Apple Eurozone Tax 348 million If there was any doubt regarding the changing international tax landscape, Apple became among the first of what is sure to be many multi-national enterprises to enter into a multi-million dollar tax settlement related to its European operations. Italy’s La Republicca announced last week that Apple has agreed to pay…
22
12 '15
Spotlight on Transfer Pricing The US Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released the much-anticipated US Country-by-Country (CbC) Reporting rules on December 21, 2015. These proposed rules, issued in the form of proposed regulation §1.6038-4, would require the ultimate US parent of a multi-national enterprise (MNE) group with annual revenues exceeding $850…
17
12 '15
Our research suggests it will, but not for a few more years.
02
12 '15
Several quarters remain before bankruptcy attorneys return to high employment. However, weakness in specific sectors should provide an increased flow of near term bankruptcy activity.
01
12 '15
Oil & Gas Price Outlook December 2015 Don’t rely upon Wall Street soothsayers — if you want to predict the future of oil & gas prices, rely on probabilities and not a crystal ball. For instance, Goldman Sachs recently made headlines when an analyst noted that $20 oil was possible next year. Analysts can run…
24
11 '15
How much is it worth to get kicked in the face? If you’re Ronda Rousey, our answer may cheer you up a bit.
17
11 '15
IRS Valuation Discounts At the American Bar Association meeting in May 2015, Cathy Hughes, Estate and Gift Tax Attorney of the US Department of Treasury’s Office of Tax Policy, commented that proposed amendments to Section 2704 (the IRS code that deals with valuation discounts) could be out by mid-September 2015. While the IRS has yet…
09
11 '15
Several quarters remain before bankruptcy attorneys return to high employment. However, weakness in specific sectors should provide an increased flow of near term bankruptcy activity.
19
10 '15
Tuomey Healthcare System has agreed to pay $72.4 million to settle its case with the U.S. government regarding illegal compensation arrangements with doctors.
29
08 '15
Sept 2015 Interest Rate Increase http://www.bloomberg.com/news/articles/2015-09-28/fed-s-dudley-says-u-s-on-track-for-2015-interest-rate-increase “The economy is doing pretty well,” Dudley said Monday at an event hosted by the Wall Street Journal in New York. “My expectation is that we probably will raise interest rates later this year.” Dudley said he expected growth in the second half will be a little bit weaker than…