Tag: US

US Treasury response to European Commission for recent State Aid Actions, 2016

US Treasury response to European Commission for recent State Aid Actions, 2016

The US Treasury in 2016 strongly criticized the European Commission for it’s state aid actions relating to US Corporations; Apple, Starbucks, Amazon, and McDonald’s. US Treasury white paper of August 2016 US White-Paper-EC-State-Aid August 24, 2016 US Treasury letter of February 2016 US Treasury letter of February 2016 EC state aid rulings ... Continue to full case

IRS vs Boston Scientific and Guidant, Settlement of $1billion dispute

Just days before trial, Boston Scientific Corp. has agreed to pay the Internal Revenue Service $275 million plus interest to settle more than $1 billion in disputed taxes dating back more than a decade. Boston Scientific has long disputed the IRS’ assertions that the company and its Guidant subsidiary have underpaid corporate taxes by as much as $1.16 billion. The dispute centers on “transfer pricing” and the amount of taxes owed to the United States for intellectual property transferred among its domestic and foreign subsidiaries. The primary issue for all years is related to transfer pricing established under technology license agreements between domestic and foreign subsidiaries of Guidant — how much one subsidiary of the company paid another for the intellectual property necessary to manufacture, sell or market medical devices ... Continue to full case
US Senate Hearings on Offshore Profit Shifting and Abusive Tax Schemes 

US Senate Hearings on Offshore Profit Shifting and Abusive Tax Schemes 

See the documents from the US Senate hearings on offshore profit shifting and abusive tax schemes https://www.hsgac.senate.gov/subcommittees/investigations/issues/tax-havens-and-abusive-tax-schemes Offshore Profit Shifting and the U.S. Tax Code – Part 1 (Microsoft & Hewlett-Packard) and Part 2 (Apple Inc.), Carl Levin’s opening statements. Profit Shifting Part 1, September 2012 OPENING, LEVIN-Carl US Senate hearing on Profit Shifting, May 2013, OPENING LEVIN-Carl ... Continue to full case
Italy vs Computer Associates SPA, February 2013, Supreme Court no 4927

Italy vs Computer Associates SPA, February 2013, Supreme Court no 4927

This case is about royalties paid by an Italian company to a US associated company. The tax authorities had challenged the inter-company royalty paid (7%) despite the fact that the taxpayer had provided an economic analysis that justified a higher royalty rate. The Supreme Court ruled in favor of the tax administration. Click here for translation Italy Supreme-Court-27-February-2013-No.-4927.pdf ... Continue to full case