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Member Articles


Microsoft’s $28.9 Billion Proposed Transfer Pricing Adjustment

The IRS in Action on Transfer Pricing On October 11, 2023, Microsoft Corporation (Microsoft) announced that it received a series of Notices of Proposed Adjustment (NOPAs) from the United States Internal Revenue Service ...

IRS Signs New Competent Authority Arrangements on NAFTA and the USMCA

U.S. taxpayers will continue to receive favorable treatment under the U.S. income tax treaties with Denmark, Luxembourg, Malta and Mexico. On July 31, 2023, the Internal Revenue Service (IRS) published competent authorit ...

Texas Legislature Approves Historic Tax Reductions

In a contentious fight that required two special sessions, the Texas House and Senate approved H.B. 3, a historic legislative package aimed at reducing property taxes and simplifying franchise tax reporting requirements ...

Qualifying Advanced Energy Project Credit Allocation Program Guidance Released

On May 31, 2023, the Internal Revenue Service issued additional detailed guidance via Notice 2023-44 for the Qualifying Advanced Energy Project Credit Allocation Program as was extended by the Inflation Reduction Act of ...

Relooking at Liquidity Risk Management Strategies

The current interest rate and economic environment have brought challenges to financial institutions in managing their liquidity risk. Effective contingency liquidity planning is essential, and financial institutions may ...

IRS Issues Statement on Export Tax for Oil Spills

In the March 6, 2023 Internal Revenue Bulletin the IRS issued a notice stating that it will acquiesce in the decision of the court in a case saying that the oil spill tax is unconstitutional as applied to exports (Trafig ...

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