News

Jerald David August Presented at the American Law Institute CLE Video Webcast Event, “Cost-Sharing Agreements: New Treasury Regulations"

On Monday, March 12, 2012, Jerald David August presented at the American Law Institute CLE Webcast Event, "Cost-Sharing Agreements: New Treasury Regulations"

In December, 2011, the Treasury issued final, temporary and proposed regulations on the transfer pricing implications and guidelines involving cost-sharing agreements (CSAs). The new regulations carry over a substantial portion of the 2009 temporary and proposed regulations (TD 9441) and adopt guidance included in the temporary regulation on the comparable uncontrolled transaction method. A CSA is an arrangement by which the participants agree to share the cost of developing one or more intangibles ("cost-sharing intangibles"). The regulations follow on the heels of several significant court cases such as Veritas Software Corp. v. Comm'r, 133 T.C. 297 (2009) and Xilinx Inc. v. Comm'r, 125 T.C. 37 (2005). The new CSA regulations play a key and critical role in the tax accounting process involving multi-national business operations in the development of intangibles and similar assets.

Read more Share

Bryan C. Skarlatos quoted in Bloomberg BNA, February 23, 2012, "Practitioners Note IRS Reversal on Paying Whistleblower Awards"

Bryan C. Skarlatos quoted in Bloomberg BNA, February 23, 2012, "Practitioners Note IRS Reversal on Paying Whistleblower Awards," by Diane Freda

Bryan C. Skarlatos quoted in Bloomberg BNA, February 23, 2012, "Practitioners Note IRS Reversal on Paying Whistleblower Awards"

Share

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "IRS Whistleblower Office Implementing Improvements"

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "IRS Whistleblower Office Implementing Improvements," by Jeremiah Coder

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "IRS Whistleblower Office Implementing Improvements"

Share

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "Parallel Criminal and Civil Investigations Require Caution Practitioners Say"

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "Parallel Criminal and Civil Investigations Require Caution Practitioners Say," by Shamik Trivedi

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "Parallel Criminal and Civil Investigations Require Caution Practitioners Say"

Share

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "IRS Ignores Comments in Final Definition of Proceeds for Whistleblower Awards"

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "IRS Ignores Comments in Final Definition of Proceeds for Whistleblower Awards," by Jeremiah Coder

Bryan C. Skarlatos quoted in Tax Analysts, Tax Notes Today, February 22, 2012, "IRS Ignores Comments in Final Definition of Proceeds for Whistleblower Awards"

Share

Sidney Kess quoted in The New York Times, Tax Tips, February 11, 2012, "Introducing Form 8949, and Other Changes"

Sidney Kess quoted in The New York Times, Tax Tips, February 11, 2012, "Introducing Form 8949, and Other Changes," by Jan M. Rosen

Sidney Kess quoted in The New York Times, Tax Tips, February 11, 2012, "Introducing Form 8949, and Other Changes"

Share

Sidney Kess quoted in The New York Times, February 11, 2012, "If You Don't File, Beware the Ghost Return"

Sidney Kess quoted in The New York Times, February 11, 2012, "If You Don't File, Beware the Ghost Return," by Charles Delafuente

Sidney Kess quoted in The New York Times, February 11, 2012, "If You Don't File, Beware the Ghost Return"

Share

Sidney Kess quoted in the New York Times, February 8, 2012, "A Year to Stay Flexible on Tax Plans"

Sidney Kess quoted in the New York Times, February 8, 2012, "A Year to Stay Flexible on Tax Plans," by Jan M. Rosen

Sidney Kess quoted in the New York Times, February 8, 2012, "A Year to Stay Flexible on Tax Plans"

Share

Bryan C. Skarlatos quoted in the Wall Street Journal, February 3, 2012, "Swiss Bank Wegelin Indicted on U.S. Tax Charges"

Bryan C. Skarlatos quoted in the Wall Street Journal, February 3, 2012, "Swiss Bank Wegelin Indicted on U.S. Tax Charges," by Chad Bray and Laura Saunders

Bryan C. Skarlatos quoted in the Wall Street Journal, February 3, 2012, "Swiss Bank Wegelin Indicted on U.S. Tax Charges"

Share

Robert S. Fink interviewed by Swiss News Agency, SDA, Swiss TV, February 1, 2012

Robert S. Fink interviewed by Swiss News Agency, SDA, Swiss TV, February 1, 2012

Share