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  • Jim Fuller David Forst Guidant v Commissioner, 146 TC No 5 (2016) is a transfer pricing case addressing the IRS's ability to make a single adjustment for a US affiliated group where different US members of the group engaged in intercompany transactions and different types of transactions occurred. In the case, six related US entities variously engaged in sales, licensing and services transactions with a large number of foreign manufacturing and distribution affiliates.
  • Jacques Kistler Rene Zulauf The Swiss House of Representatives voted on the Swiss Corporate Tax Reform III (CTR III) on March 16 and 17. The House voted, among others, in favour of the following replacement measures to compensate for the abolition of special income tax regimes:
  • Alexander Linn Thorsten Braun In a decision dated December 15 2015 (and published on February 12 2016), Germany's constitutional court (BVerfG) confirmed that the legislature can enact tax treaty override provisions that aim to secure Germany's taxation rights, despite treaty provisions to the contrary.
  • Anyone who was around in the Middle Ages can attest that soap deserved an exemption as an essential good. Especially when considering number 3 in the list Some of the strange taxes from history make modern taxes seem almost desirable. Tax avoidance may be hitting today's headlines, but trying to avoid tax has existed as long as tax itself.
  • Anna Pushkaryova The Ministry of Finance of Georgia has recently initiated important changes in the system of corporate income taxation, particularly related to the moment of taxation itself.
  • Negotiations for fictitious Budget funding from the US to Canada have hit a brick Wall in Mexico In an all-party parliamentary vote this month, the US Congress has passed a movement to send a cheque to the Canadian Prime Minister, Justin Trudeau, for his 2016 Budget.
  • Retailer Walmart has won a $100 million tax case against the Puerto Rican Government in controversial circumstances. The multinational is the largest private sector employer in Puerto Rico.
  • In May 2015, TP Week surveyed in-house tax professionals and found that 54% of them have been proactively taking steps to prepare for BEPS implementation.
  • James Karanja has been appointed as the new head of the OECD and UN Development Programme initiative, Tax Inspectors Without Borders (TIWB). He is expected to commence the role on April 11 2016.
  • Andrew Dickson will join the private client practice as a senior associate in Osborne Clarke's London office.
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