Expand the following panels for additional search options.

Gift and Estate Tax Valuation Update

Join Barry Sziklay for important 2021 income and transfer tax valuation cases as well as the valuation aspects of the adequate disclosure regulations required to report a gift for federal transfer tax purposes and start the statute of limitations running. Internal Revenue Code (IRC) Chapter 14 valuations, Special Valuation Rules §§ 2701-2704, will be addressed in a summary fashion given the complexities of the rules required for a valuation to meet the requirements of Chapter ...

Medtronic, Inc. v. Commissioner (II)

8th Circuit says Tax Court failed to do the required comparability analysis between selected uncontrolled license arrangement and contested intercompany licenses, making it impossible to say whether CUT was the best method for calculating arm’s-length royalty rates in transfer pricing case.

In Transfer Pricing Case, Tax Court Fails to Perform Adequate CUT Analysis

In transfer pricing case centering on taxpayer’s intercompany licensing agreements, Tax Court finds CUT method is the best way to calculate arm’s-length royalty rates; court accepts taxpayer-proposed uncontrolled comparable but makes adjustments to account for differences in transactions.

Medtronic, Inc. v. Commissioner (I)

In transfer pricing case centering on taxpayer’s intercompany licensing agreements, Tax Court finds CUT method is the best way to calculate arm’s-length royalty rates; court accepts taxpayer-proposed uncontrolled comparable but makes adjustments to account for differences in transactions.

4 results