Brown Group revisited

Article Abstract:

Taxpayers hoping to reap the benefits of deferral by depending on the US Court of Appeals for the 8th Circuit's holding in Brown Group should be aware that the IRS is likely to enforce aggregate treatment at least outside of the 8th Circuit's jurisdiction. The conflict concerns how Subchapter K partnership provisions are to be interpreted with Subpart F controlled foreign corporation sections. Since the check-the-box entity regulations could result in more entities being classified as partnerships, a modified Brown Group structure is advisable to those who seek similar deferral.

United States, Partnership, Partnerships

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OECD transfer pricing guidelines update: challenges for taxpayers and tax authorities

Article Abstract:

The Organization for Economic Cooperation and Development (OECD) report "Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations" signals important developments in OECD thinking on the application of the arms-length principle to intercompany transfers of intangible property and services. These developments lie in the potential for developing marketing intangibles separate from trademarks and trade names, the chance to adjust retroactively the terms of intangible transfers and to transfer services at cost.

Reports, International aspects, Organization for Economic Cooperation and Development, Transfer pricing, international

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