Sentences with phrase «transfer pricing issues»

Dr. Chandler has assisted taxpayers with transfer pricing issues at audit and appeals in the United States and other countries, as well as by providing expert testimony in Tax Court.

The team acts for a range of domestic and multinational companies, advising on the tax aspects of business operations, transactional activity and transfer pricing issues.

Earlier this year the OECD published «Addressing Base Erosion and Profit Shifting,» which looked at the root causes of BEPS and six pressure areas including the residence - source tax balance (particularly in a digital economy), transfer pricing issues, the effectiveness of anti-avoidance rules, and the existence of preferential regimes.

Experience in Canada suggests that resolving transfer pricing issues will be long and difficult.

Transfer pricing issues have become a significant political issue as the G - 20 nations focus on ways to combat double non-taxation

He is well known for bringing insight to tax controversies and transfer pricing issues.

Related Matters - We also specialize in a number of other tax and trade related areas, including the tax, customs and competition issues arising on the establishment of a business in Canada; the valuation and transfer pricing issues arising between multinational enterprises; the issues arising on the transfer of business personnel to Canada; disputes relating to employee vs. independent contractor status under Canada's various federal and provincial tax legislation; and on all other matters relating to the cross-border movement of goods, services and labour.

In addition to a deep - dive on the impact of U.S. tax reform, we'll also address the OECD's work on financial transactions, key developments in taxation of the digital economy and expert insights and analysis on key transfer pricing issues including BEPS, country - by country reporting, attribution of profits to PE's, APA's, the MLI and more.

Not exact matches

«If we substitute a tax on marijuana cigarettes equal to the difference between the local production cost and the street price people currently pay — that is, transfer the revenue from the current producers and marketers (many of whom work with organized crime) to the government, leaving all other marketing and transportation issues aside we would have revenue of (say) $ 7 per [unit].

The summary of issues explores various considerations arising in developing an internationally accepted and applied «template» for country - by - country reporting as a part of transfer pricing documentation, and considers accounting requirements and other information as the base for the information which might be included in the template.

Historically, for shareholders participating in the DRIP, American Stock Transfer & Trust Company, LLC (the «Plan Agent») used cash dividends to purchase shares of NHF in the secondary market when the price of NHF's shares, plus estimated brokerage commissions, was less than NAV, or distributed newly issued common shares when the price of NHF's shares, plus estimated brokerage commissions, was equal to or greater than NAV.

However, it is reasonably possible that certain federal, foreign and state tax issues may be concluded in the next 12 months, including issues involving transfer pricing and other matters.

There are however concerns about his attitude and the real issue Arsenal have here is that there is plenty of competition for the Belgian and at such a commanding transfer fee, (likely to be # 50m +) I think the Gunners may be priced out of the market.

Tickets prices are an issue and any unspent money from our yearly transfer found should at least be used in reducing them.

This is a rare transfer case with us that isn't being dragged out because of price, it's down to work permit issues.

Well, tickets prices are an issue and any unspent money from our yearly transfer found should at least be used in reducing them.

Time for some brutal honesty... this team, as it stands, is in no better position to compete next season than they were 12 months ago, minus the fact that some fans have been easily snowed by the acquisition of Lacazette, the free transfer LB and the release of Sanogo... if you look at the facts carefully you will see a team that still has far more questions than answers... to better show what I mean by this statement I will briefly discuss the current state of affairs on a position - by - position basis... in goal we have 4 potential candidates, but in reality we have only 1 option with any real future and somehow he's the only one we have actively tried to get rid of for years because he and his father were a little too involved on social media and he got caught smoking (funny how people still defend Wiltshire under the same and far worse circumstances)... you would think we would want to keep any goaltender that Juventus had interest in, as they seem to have a pretty good history when it comes to that position... as far as the defenders on our current roster there are only a few individuals whom have the skill and / or youth worthy of our time and / or investment, as such we should get rid of anyone who doesn't meet those simple requirements, which means we should get rid of DeBouchy, Gibbs, Gabriel, Mertz and loan out Chambers to see if last seasons foray with Middlesborough was an anomaly or a prediction of things to come... some fans have lamented wildly about the return of Mertz to the starting lineup due to his FA Cup performance but these sort of pie in the sky meanderings are indicative of what's wrong with this club and it's wishy - washy fan - base... in addition to these moves the club should aggressively pursue the acquisition of dominant and mobile CB to stabilize an all too fragile defensive group that has self - destructed on numerous occasions over the past 5 seasons... moving forward and building on our need to re-establish our once dominant presence throughout the middle of the park we need to target a CDM then do whatever it takes to get that player into the fold without any of the usual nickel and diming we have become famous for (this kind of ruthless haggling has cost us numerous special players and certainly can't help make the player in question feel good about the way their future potential employer feels about them)... in order for us to become dominant again we need to be strong up the middle again from Goalkeeper to CB to DM to ACM to striker, like we did in our most glorious years before and during Wenger's reign... with this in mind, if we want Ozil to be that dominant attacking midfielder we can't keep leaving him exposed to constant ridicule about his lack of defensive prowess and provide him with the proper players in the final third... he was never a good defensive player in Real or with the German National squad and they certainly didn't suffer as a result of his presence on the pitch... as for the rest of the midfield the blame falls squarely in the hands of Wenger and Gazidis, the fact that Ramsey, Ox, Sanchez and even Ozil were allowed to regularly start when none of the aforementioned had more than a year left under contract is criminal for a club of this size and financial might... the fact that we could find money for Walcott and Xhaka, who weren't even guaranteed starters, means that our whole business model needs a complete overhaul... for me it's time to get rid of some serious deadweight, even if it means selling them below what you believe their market value is just to simply right this ship and change the stagnant culture that currently exists... this means saying goodbye to Wiltshire, Elneny, Carzola, Walcott and Ramsey... everyone, minus Elneny, have spent just as much time on the training table as on the field of play, which would be manageable if they weren't so inconsistent from a performance standpoint (excluding Carzola, who is like the recent version of Rosicky — too bad, both will be deeply missed)... in their places we need to bring in some proven performers with no history of injuries... up front, although I do like the possibilities that a player like Lacazette presents, the fact that we had to wait so many years to acquire some true quality at the striker position falls once again squarely at the feet of Wenger... this issue highlights the ultimate scam being perpetrated by this club since the arrival of Kroenke: pretend your a small market club when it comes to making purchases but milk your fans like a big market club when it comes to ticket prices and merchandising... I believe the reason why Wenger hasn't pursued someone of Henry's quality, minus a fairly inexpensive RVP, was that he knew that they would demand players of a similar ilk to be brought on board and that wasn't possible when the business model was that of a «selling» club... does it really make sense that we could only make a cheeky bid for Suarez, or that we couldn't get Higuain over the line when he was being offered up for half the price he eventually went to Juve for, or that we've only paid any interest to strikers who were clearly not going to press their current teams to let them go to Arsenal like Benzema or Cavani... just part of the facade that finally came crashing down when Sanchez finally called their bluff... the fact remains that no one wants to win more than Sanchez, including Wenger, and although I don't agree with everything that he has done off the field, I would much rather have Alexis front and center than a manager who has clearly bought into the Kroenke model in large part due to the fact that his enormous ego suggests that only he could accomplish great things without breaking the bank... unfortunately that isn't possible anymore as the game has changed quite dramatically in the last 15 years, which has left a largely complacent and complicit Wenger on the outside looking in... so don't blame those players who demanded more and were left wanting... don't blame those fans who have tried desperately to raise awareness for several years when cracks began to appear... place the blame at the feet of those who were well aware all along of the potential pitfalls of just such a plan but continued to follow it even when it was no longer a financial necessity, like it ever really was...

Typically, 2 % of the purchase price is deducted from the sale and is transferred from the merchant's bank («acquiring bank») to the customer's bank («issuing bank»).

Under the terms of the Advisory Agreement, each Fund is responsible for the payment of the following expenses among others: (a) the fees payable to the Adviser, (b) the fees and expenses of Trustees who are not affiliated persons of the Adviser or Distributor (as defined under the section entitled («The Distributor»)(c) the fees and certain expenses of the Custodian (as defined under the section entitled «Custodian») and Transfer and Dividend Disbursing Agent (as defined under the section entitled «Transfer Agent»), including the cost of maintaining certain required records of the Fund and of pricing the Fund's shares, (d) the charges and expenses of legal counsel and independent accountants for the Fund, (e) brokerage commissions and any issue or transfer taxes chargeable to the Fund in connection with its securities transactions, (f) all taxes and corporate fees payable by the Fund to governmental agencies, (g) the fees of any trade association of which the Fund may be a member, (h) the cost of fidelity and liability insurance, (i) the fees and expenses involved in registering and maintaining registration of the Fund and of shares with the SEC, qualifying its shares under state securities laws, including the preparation and printing of the Fund's registration statements and prospectuses for such purposes, (j) all expenses of shareholders and Trustees» meetings (including travel expenses of trustees and officers of the Trust who are not diTransfer and Dividend Disbursing Agent (as defined under the section entitled «Transfer Agent»), including the cost of maintaining certain required records of the Fund and of pricing the Fund's shares, (d) the charges and expenses of legal counsel and independent accountants for the Fund, (e) brokerage commissions and any issue or transfer taxes chargeable to the Fund in connection with its securities transactions, (f) all taxes and corporate fees payable by the Fund to governmental agencies, (g) the fees of any trade association of which the Fund may be a member, (h) the cost of fidelity and liability insurance, (i) the fees and expenses involved in registering and maintaining registration of the Fund and of shares with the SEC, qualifying its shares under state securities laws, including the preparation and printing of the Fund's registration statements and prospectuses for such purposes, (j) all expenses of shareholders and Trustees» meetings (including travel expenses of trustees and officers of the Trust who are not diTransfer Agent»), including the cost of maintaining certain required records of the Fund and of pricing the Fund's shares, (d) the charges and expenses of legal counsel and independent accountants for the Fund, (e) brokerage commissions and any issue or transfer taxes chargeable to the Fund in connection with its securities transactions, (f) all taxes and corporate fees payable by the Fund to governmental agencies, (g) the fees of any trade association of which the Fund may be a member, (h) the cost of fidelity and liability insurance, (i) the fees and expenses involved in registering and maintaining registration of the Fund and of shares with the SEC, qualifying its shares under state securities laws, including the preparation and printing of the Fund's registration statements and prospectuses for such purposes, (j) all expenses of shareholders and Trustees» meetings (including travel expenses of trustees and officers of the Trust who are not ditransfer taxes chargeable to the Fund in connection with its securities transactions, (f) all taxes and corporate fees payable by the Fund to governmental agencies, (g) the fees of any trade association of which the Fund may be a member, (h) the cost of fidelity and liability insurance, (i) the fees and expenses involved in registering and maintaining registration of the Fund and of shares with the SEC, qualifying its shares under state securities laws, including the preparation and printing of the Fund's registration statements and prospectuses for such purposes, (j) all expenses of shareholders and Trustees» meetings (including travel expenses of trustees and officers of the Trust who are not directors,

The effects of oil price on the development of renewables and the global distribution of consumption is likely to be convoluted and issues such as trade and technology transfer will be of great importance.

Litigation in the US Tax Court, the US Court of Federal Claims, and multiple federal district and appellate courts, with experience ranging from partnership tax litigation, research and development credit litigation, fringe benefits and payroll tax litigation, transfer pricing litigation, and numerous other domestic and international issues

Our transfer pricing team has represented US and foreign - based multinational enterprises in some of the largest, most complex, and important transfer pricing disputes in recent history, including serving as lead counsel to Amazon.com in its significant win in the US Tax Court involving a cost - sharing buy - in and related issues — one of the largest transfer pricing cases ever litigated and the first involving e-commerce.

Sheppard Mullin assists clients in the life sciences industry with strategic issues that range from acquisitions to antitrust, entity formation to enforceability evaluations, licensing to litigation, patents to product liability, and trademarks to transfer pricing.

Although the transfer pricing provisions were enacted in 1997, there has only been one case before the courts where transfer pricing penalties were specifically at issue (Marzen Artistic Aluminum Ltd. v Canada, 2016 FCA 34; aff» g. 2014 TCC 194).

For instance, when I represented an equity investor, I had to handle issues concerning reassessment of equity price; when I acted for Schindler Elevator, I had to figure out issues concerning deficiency of design, manufacturing and installation; when I assisted CapitalMalls Asia in its real estate - related disputes, I had to research foreign investment regulation, restrictions and administrative approval on real estate transfer.

Second, the moving parties argued that Justice Newbould erred in finding that an agreement which addressed transfer pricing tax issues between certain Nortel debtors while they were engage in ongoing operations (the «Master R&D Agreement» or «MRDA»), and which had formed the basis of the appellants» theory of allocation at trial, was never intended to and did not govern the allocation of the Lockbox Funds.

Acted for numerous airlines advising them on regulatory issues, and claims of both regulatory and commercial nature including EC 261 claims, advice on compliance with various EU Regulations including ETS, EC Reg 1008/2008, the PRM Regulation, state aid, consumer protection legislation, competition cartel and alliance issues, price fixing investigations, disputes with airports, slots advice and transfers, EU blacklist work and regulatory safety compliance, ground handling disputes, and commercial disputes acting for airlines against all manner of suppliers and manufacturers.

It's really beneficial on an issue like transfer pricing to have all three disciplines in one organization.

The fact that the adjustments resulted from a voluntary disclosure and the Minister had chosen not to audit Sifto before issuing the First Reassessments did not change the fact that the Agreements necessarily determined the transfer price of the rock salt.

In his decision, Justice Owen considered a number of questions, including: (i) what issue the Agreements had resolved; (ii) whether a settlement had been reached by Sifto and the Minister; (iii) whether the settlement fixed the transfer price of the rock salt; and (iv) whether the Minister was required to issue the Second Reassessments notwithstanding the settlement that had been reached with Sifto.

These areas include: doing business abroad, including through low tax jurisdictions; the remittance of foreign earnings from foreign subsidiaries of Canadian corporations; planning for interaction with Canada's network of international tax treaties and international tax issues; transfer pricing; personal emigration from and immigration to Canada; customs planning, including customs valuations, tariff classification and rules of origin considerations.

Additionally, we advise on income tax, commodity tax and cross-border tax issues, including transfer pricing, marketing and advertising, privacy, employment and real estate matters.

Our International Tax team routinely advises clients on both outbound and inbound tax issues involved with cross-border mergers and acquisitions, financing transactions, planning issues, treaty issues, and transfer pricing matters.

My primary research interests focus on global taxation issues (e.g., tax treaties, transfer pricing), international capital movement, wealth management and financial planning, and anti-money laundering.

Samuel Maruca participated in a panel at the annual Institute on Current Issues in International Taxation event, and is quoted in a Law360 article regarding the current state of transfer pricing rules.

AstraZeneca v HMRC David Bedenham was instructed by HMRC in this long running dispute relating to transfer pricing and controlled foreign company issues.

We increasingly see transfer pricing as a significant issue in due diligence in corporate finance and M&A transactions.

«They will seek to deal with the person who they think is the best to deal with the issue, especially in transfer pricing cases,» he says.

Mr. Murphy's substantive experience includes a wide range of complex tax issues, including economic substance and business purpose, foreign tax credits, debt / equity, transfer pricing and a variety...

Transfer pricing Avoiding transfer pricing disputes, or achieving favorable resolutions when they do arise, requires a comprehensive understanding of the transfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be adTransfer pricing Avoiding transfer pricing disputes, or achieving favorable resolutions when they do arise, requires a comprehensive understanding of the transfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be adtransfer pricing disputes, or achieving favorable resolutions when they do arise, requires a comprehensive understanding of the transfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be adtransfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be addressed.

PwC Legal (PricewaterhouseCoopers Legal CIS B.V.) primarily handles tax audits and disputes and administrative issues involving VAT, transfer pricing and cross-border transactions.

AstraZeneca v HMRC Long running dispute relating to transfer pricing and controlled foreign company issues.

Property Management — Duties & Responsibilities Coordinate regular maintenance and repairs as well as emergency resolution through the efficient management of maintenance team and general / sub-contractors, also participating in restoration and renovation projects to ensure timely completion within designated budgets Develop annual property budget and monitor with monthly variance reports, preparing financial statements and various regular and ad - hoc reports on property status, including occupancy rates and lease expirations Provide relevant oversight and administration to tenant build - outs, utility service termination and transfer, supply purchasing, and building consolidation processes Support firm management to aid in effective customer service, maintenance, and general property operations, delegating important tasks and assignments while overseeing all critical management aspects Organize, manage, and execute all aspects of the lease process, facilitating the ease of operational aspects as well as price / term negotiations, rental agreement reviews, rent collection, impounds, and tenant eviction as necessary Generate increased revenue through tenant referrals as well as consistent lease renewals through effective service and timely issue resolution Identify and develop talent among hired staff and property personnel, utilizing focused training efforts within a performance - based work environment designed to utilize the critical strengths of assistants, supervisors, and techs Provide continuous assessment of property usage and needs, while furnishing oversight and guidance regarding effective preventative maintenance programs, renovation considerations, and cost reduction / control measures Maintain a strong working knowledge of the leasing property, respective marketplace, and general economic trends Act as a liaison between clients, vendors, sales personnel, support staff, and senior management to facilitate information flow and drive operational efficiency

Case law varies on this issue, but it's universally acceptable to condition commission on a particular event such as the transfer of a deed or the payment of the purchase price.