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Full-Text Articles in Business
Apple’S Cost-Sharing Arrangement: Frankenstein’S Monster, David G. Chamberlain, Stephen L. Curtis
Apple’S Cost-Sharing Arrangement: Frankenstein’S Monster, David G. Chamberlain, Stephen L. Curtis
Accounting
In this two-part report, Curtis and Chamberlain break down Apple’s cost-sharing arrangement and explain how corporate taxpayers have been able to exploit the cost-sharing regulations to shift hundreds of billions or even trillions in U.S. profits offshore with little or no IRS detection or enforcement.
How The Tax Court Can Account For Risk In Medtronic Transfer Pricing, David G. Chamberlain
How The Tax Court Can Account For Risk In Medtronic Transfer Pricing, David G. Chamberlain
Accounting
In this report, Chamberlain explores how the Tax Court, on remand in Medtronic, can address the challenge of determining arm’s-length transfer prices when one of the related parties bears substantial risk but owns no valuable intangible property.
Disappearing Forks And Magical Airdrops, David G. Chamberlain, Rodney P. Mock, Kathryn Kisska-Schulze
Disappearing Forks And Magical Airdrops, David G. Chamberlain, Rodney P. Mock, Kathryn Kisska-Schulze
Accounting
In this article, the authors argue that the IRS misguides taxpayers because it confuses cryptocurrency hard forks and airdrops in newly issued Rev. Rul. 2019-24.
Section 199a: Job Creator Or Tax Giveaway?, Rodney P. Mock, David G. Chamberlain
Section 199a: Job Creator Or Tax Giveaway?, Rodney P. Mock, David G. Chamberlain
Accounting
In this report, Mock and Chamberlain discuss section 199A and its inconsistencies regarding job creation policy.