India’s proposed reforms to permanent establishment and profit attribution rules will provide certainty to foreign companies doing business in India.

A recent CJEU ruling provides welcome guidance to companies regarding transfer pricing adjustments and their VAT implications.

Cross-border telework present employers with heightened risks and require careful handling to avoid unintended tax consequences related to permanent establishment.

Strategies for navigating a new era of customs enforcement and the latest developments are discussed.

An economist presents real-world examples of how tariffs and transfer pricing collide.

Investors may not appreciate the stakes of Coca-Cola’s long-running transfer pricing battle with the IRS.

The plan for restructuring DOJ’s Tax Division may further degrade tax compliance.

The alternative safeguards identified in the Supreme Court’s Cunningham v. Cornell decision are discussed for avoiding costly time-intensive discovery for ultimately meritless ERISA claims.

OBBBA reduces the income tax benefit of claiming a charitable deduction, prompting donors to reconsider tax implications when deciding between making a nondeductible contribution to a social welfare “lobbying” organization or a deductible contribution to a “charity” organization.

The IRS issued new guidance that would appear to lessen CAMT burdens for many large corporations, but the book-based tax regime remains exceedingly complex.

Postseason baseball is a metaphor for practitioners seeking relief for a late allocation or election under §2642(g)(1).

In light of recent Puerto Rico and IRS guidance, some practical considerations on how the SECURE 2.0 Act changes to the Puerto Rico qualified retirement plan rules are analyzed.