A Model of Transfer Pricing Conflicts Between Revenue Canada and the Internal Revenue Service

1997 ◽  
Author(s):  
Richard C. Sansing
Keyword(s):  
Transfer Pricing ◽  
Internal Revenue Service ◽  
Internal Revenue

GlaxoSmithKline Plc.: International Transfer Pricing and Taxation

2007 ◽  
Vol 22 (4) ◽  
pp. 749-759
Author(s):  
Mahendra R. Gujarathi
Keyword(s):  
Multinational Corporations ◽  
Intangible Assets ◽  
Transfer Pricing ◽  
Tax Credits ◽  
Internal Revenue Service ◽  
Internal Revenue ◽  
The U.S

This comprehensive case intends to develop your understanding of the complexities involved in the international transfer pricing and taxation of intangible assets. The backdrop for the case is GlaxoSmithKline's $5.2 billion settlement in 2006 with the U.S. Internal Revenue Service. You are required to provide possible rationales for the positions advocated by the Company as well as the IRS. You are also required to present calculations under different transfer pricing methods, identify the most appropriate method, compute Foreign Tax Credits for different scenarios, and suggest possible strategies for multinational corporations to reduce the odds of negative settlements with tax authorities.

Tax Practitioner Credentials and the Incidence of IRS Audit Adjustments

2003 ◽  
Vol 17 (1) ◽  
pp. 1-14 ◽  
Author(s):  
Peggy A. Hite ◽  
John Hasseldine
Keyword(s):  
Random Selection ◽  
Internal Revenue Service ◽  
Internal Revenue ◽  
Tax Returns ◽  
Selection Of

This study analyzes a random selection of Internal Revenue Service (IRS) office audits from October 1997 to July 1998, the type of audit that concerns most taxpayers. Taxpayers engage paid preparers in order to avoid this type of audit and to avoid any resulting tax adjustments. The study examines whether there are more audit adjustments and penalty assessments on tax returns with paid-preparer assistance than on tax returns without paid-preparer assistance. By comparing the frequency of adjustments on IRS office audits, the study finds that there are significantly fewer tax adjustments on paid-preparer returns than on self-prepared returns. Moreover, CPA-prepared returns resulted in fewer audit adjustments than non CPA-prepared returns.

The Effects of Capital Campaigns on Local Nonprofit Ecologies

2018 ◽  
Vol 47 (3) ◽  
pp. 645-656 ◽  
Author(s):  
Joanna Woronkowicz
Keyword(s):  
Nonprofit Organizations ◽  
Internal Revenue Service ◽  
Arts Organizations ◽  
Natural Distribution ◽  
Capital Campaign ◽  
Internal Revenue ◽  
Capital Campaigns ◽  
Short Period ◽  
Distribution Of Resources ◽  
Nonprofit Arts

When charities launch capital campaigns, they hope to attract large amounts of resources in a relatively short period of time; however, other charities in the area are likely to see such campaigns as disruptive to the natural distribution of resources to area nonprofits by disproportionately directing area donations to a single organization. This study seeks to understand the effects capital campaigns have on both the fundraising performance of other nonprofits and the makeup of a local nonprofit ecology. The analysis uses data from a randomly sampled set of nonprofit arts organizations that had capital campaigns for facilities projects between 1994 and 2007 and Internal Revenue Service Form 990 data on 501 (c) (3) nonprofit organizations in each county. The results illustrate that a capital campaign positively affects the fundraising performance of other charities in a local nonprofit ecology, but that campaigns decrease the size of a local nonprofit ecology.

ALAS, POOR MELVIN

PEDIATRICS ◽  
1989 ◽  
Vol 83 (6) ◽  
pp. A80-A80
Author(s):  
R. J. M.
Keyword(s):  
San Francisco ◽  
Office Building ◽  
Internal Revenue Service ◽  
Court Order ◽  
Bone China ◽  
Internal Revenue ◽  
Dining Room ◽  
Tax Court

Sausalito, CA—Come dinner time aboard his yacht Adequate Award, and Melvin Belli really knows how to put on the dog. Tonight, his dining-room table is set with bone china and sterling silver, and browsing among the tableware is one hungry Italian greyhound. I know the animal is hungry because he has walked across the table and taken a bite of my bread plate. . . There are those who would have you believe that Mr. Belli, the King of Torts, has become so eccentric that more than dinner is becoming chaotic. . . Since summer, the 81-year-old lawyer has been barred by court order from his 25-room San Francisco mansion. His wife got the order after filing a petition for legal separation. She complained at the time to reporters and police that Mr. Belli physically and verbally abused her and their teenage daughter. Even more bizarre, she claims that he falsely accused her of having sex with a number of family friends, including celebrities of both sexes. . . Another shot fired across the bow: In a lawsuit pending in Tax Court, the Internal Revenue Service contends that Mr. Belli, in effect, back-dated documents to avoid paying gift taxes in a transaction involving his San Francisco law-office building. . . His firm, Law Offices of Melvin Belli, Sr., is on trial, too, these days. Three years ago, Mr. Belli lost a malpractice case resulting in a $3.8 million judgement against him. Since then, six more malpractice suits have been filed against him in San Francisco Superior Court. . .

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