Knowledge Base

The Spanish Supreme Court, in its judgment of June 20, 2016 (Dell Case) , stated that an Irish tax resident company operated in Spain through a permanent establishment (PE), developing its Spanish operations through its Spanish...Read more >

On 2 December 2016 the Spanish Government approved Royal Decree Law 3/2016 introducing important changes to Spanish Corporate Income Tax Law and other taxes.

A summary of the most relevant measures are the following:

Corporate Income Tax:

Prohibition to deduct losses...Read more >

Election Results and the Policy Agenda

On November 8th, Donald Trump was elected the 45th president of the United States. During the transition period until inauguration day on January 20, 2017, he is working to assemble a team of advisors and cabinet members. President-elect Trump...Read more >

With the election of Donald J. Trump as the 45th President of The United States of America on November 8th along with GOP control of both the House of Representatives and the Senate, our country is now in a position with an aligned party to eliminate gridlock (possibly?). While tax reform has...Read more >

Large multinational enterprises operating in the United States may soon face a significant addition to their transfer pricing compliance requirements. According to the U.S. Treasury Office of International Tax Counsel, the Internal Revenue Service (“IRS”) plans to implement the guidance provided...Read more >

In a unanimous, reviewed decision released on July 27, 2015, the U.S. Tax Court, in Altera Corporation and Subsidiaries v. Commissioner, 145 T.C. No. 3, has held that the requirement in the final section 482 cost sharing regulations that stock-based compensation be included in the intangible...Read more >

Background

After several weeks of uncertainty about the leadership of the Republican party in the House and the resolution of several key fiscal issues with looming deadlines, October ends with the election of Congressman Paul Ryan (R-WI) as the new Speaker of the House and the approval of a...Read more >

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