International Taxation

The United States Department of Justice Tax Division (DOJ) has announced they are open to talk with any foreign financial institution that would like to resolve potential U.S. tax exposure. Acting Assistant Attorney General, Caroline Ciraolo, stated that institutions outside of the formal Swiss Bank Program should consider meeting with the DOJ to attempt to…

On Dec. 14, 2015, Coca-Cola filed a petition in the U.S. Tax Court fighting a proposed $9.4 billion transfer pricing adjustment by the IRS. Among the many items being challenged by the Service are royalty payments made to Coca-Cola from a licensee in Mexico resulting in foreign tax credits (FTC). Now, two years to the…