Can I Charge An Interest Rate On Intercompany Loans That Is Different From The Safe Harbor Rate?
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How Can I Replace One Transfer Pricing System With Another System Without Raising Red Flags?
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The Field Audit Team Has Proposed A Transfer Pricing Adjustment. What Are My Options To Fight The Adjustments?
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Under What Circumstances Will The Sale Of Intellectual Property ("IP") By A Controlled Foreign Corporation ("CFC") Give...
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Are There Any Transaction Structures That Can Be Utilized By A US Corporation To Repatriate Low-taxed Offshore Cash In The Context Of The...
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Does Liability Assumption Reduce The Amount Of Gain Recognized Under Section 356(a)(1) In The Same Manner As It Does Under Section 301?
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What Must Be Done To Obtain Hedging Treatment For US Federal Income Tax Purposes, And What Is The Benefit Of Obtaining Hedging Treatment?
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What Are The Estimated Tax And Tax Return Filing Requirements For Taxpayers Earning Income As An Independent Contractor And Should I...
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My Corporation Is Expanding Into Asia And Europe. What Type Of Holding Company And Entity Structure Will Result In The Lowest Possible...
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If I Have Bank Accounts Or Other Property Outside The U.S., What U.S. Reporting Is Required To Be Fully Compliant With All U.S. Laws?
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How Long Can I Stay In The U.S. And How Much Income Can I Earn In The U.S. Before I Have To Pay U.S. Taxes And File U.S. Tax Returns? How...
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My Company Purchased An Office Building About 45 Years Ago For $5,000. The Company Is A Sub-chapter S Corp So Everything Flows Through To...
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Under The New FATCA Regime, Will Gross Proceeds From The Sale Of U.S. Securities Be Considered A "withholdable Payment"? If So,...
Asked in California, United States