International Tax

Regulation Changes for Reorganizations Involving Foreign Corporations

By Cynthia Hoffman | May 09, 2013

The U.S. Treasury Department recently issued regulations with guidance on cross-border reorganizations under I.R.C. Sections 367, 1248 and 6038B. The regulations

International Tax

Japan Tax Reform Proposal

By Ken Kobayashi | February 14, 2013

On January 29, 2013, the Japan Cabinet Office's Tax Commission submitted its 2013 tax reform proposal. The tax reform proposal will be submitted to Diet

International

US and Japan Protocol Finalized

By Ken Kobayashi | January 30, 2013

Representatives of the governments of the United States and Japan signed a new Protocol to the United States-Japan income tax treaty on January 24, 2013.

International Tax

Transfer Pricing Update - Japan

By Mary Richter | October 24, 2012

As in many countries, Japan's tax authorities have focused on transfer pricing in tax audits. These audits are separate from general tax audits, although,

International Tax

Current List of Countries Requiring Participation in International Boycott Released: Now Includes Iraq

By Cynthia Hoffman | September 12, 2012

On August 15, 2012, the IRS published the updated list of countries that require or may require participation in, or cooperation with, an international

Insights