we previously posted on March 27, 2017 Amazon Defends It's Pricing and Tax Court Issues the IRS its 2nd Large §482 Defeat On January 5, 2015 we where we discussed that the US Tax Court ruled against the IRS in this $1.5 billion transfer pricing dispute with Amazon, which currently has experts calling for a re-examination of…
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Apple States That Its Irish Subsidiaries Should be Taxed in the US & US Gov't Agrees To Intervene In Apple's €13B EU Tax Case
Apple has published its defense to the European Commission's accusation that it obtained unfair commercial advantage from its corporation tax agreement with Ireland. The company states that its profit-making activities were controlled and managed in the US, and so should be taxed there and not in Ireland; and that the Commission has breached Apple's 'fundamental…
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The US Is Now Revoking Passports of US Taxpayers Who Have Unpaid Taxes!
On March 1, 2017 we posted Another Travel Ban: Starting Next Month Your US Passport Will Be Revoked For Tax Debts! where we discussed that the tax code now provides for authorities to revoke or deny the passport of any US taxpayer who has unpaid taxes in excess of $50,000 or who have not obtained or…
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IRS Targeting Foreign Corporations Which Do Not File!
On February 7, 2017 we posted IRS Has 13 New Compliance Campaigns for LB&I Taxpayers where we discussed that Tax practitioners will face new questions from examination teams as the IRS selects compliance risks based on data, in the Large Business and International Division's (LB&I) move from individual audits of multinationals to broader considerations involving…
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