Author Page: Christine Long — Ruchelman P.L.L.C.

articles from insights

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European State Aid: The Makings of A Global Trade War

The 2016 U.S. Model Income Tax Treaty

E.U. State Aid – The Saga Continues

U.S. Tax Residency Certification and Spanish Withholding Tax: Early Application Recommended

On the Blacklist – Is Delaware a Tax Haven?

Final Regulations Limit Importation of Built-In Losses

2016 Model Treaty – Special Tax Regimes

Apple in Europe – The Uphill Battle Continues

B.E.P.S. Initiative Spawns Unfavorable Permanent Establishment Court Decisions

International Practice Unit: License of Intangible Property from U.S. Parent to a Foreign Subsidiary

International Practice Unit: Deemed Annual Royalty Income Under Code §367(d)

P.A.T.H. Act Leads to Widespread Tax Changes

Mylan's Opposition to the I.R.S. – No Substantial Rights

I.R.S. Argues Mylan's Contract is a License of Drug Rights – Not a Sale

Temporary Regulations Alter C.F.C.'s Active Rents and Royalties Exception to Subpart F

Proposed P.F.I.C. Exception Regulations Detrimental to Foreign Insurers

S.T.A.R.S. Transactions – Interest Deduction Allowed but Foreign Tax Credit Disallowed

Eaton Corp.'s Transfer Pricing Trial Begins August 24

U.K. Implements 25% “Google Tax” on Diverted Profits

India’s $6.4 Billion Tax on Foreign Investment

Economic Distortions Arising from Deferral

Major U.S. Drug Company Avoids Billions in Taxes on $1,000 Pill

New Centralized Approach to International Audits

Insights Vol. 2 No. 2: Updates & Other Tidbits

Follow-Up Draft of Report on Action 6 (Treaty Abuse) and Public Comments Released

Insights Vol. 2 No. 1: Updates & Other Tidbits

B.E.P.S. Actions 8, 9 & 10: Assuring that Transfer Pricing Outcomes are in Line with Value Creation