Transfer Pricing: Current issues
The 2017 Tax Reform Act added a new third sentence to ยง 482 that allows aggregation and the consideration of realistic alternatives if it produces the most reliable means of valuation29/03/2018
Jim Fuller is a partner in the Tax Group at Fenwick & West LLP in Mountain View, California. He is one of the world's top 30 tax advisers, according to Euromoney.
Fuller appears in in Euromoney's "Best of the Best USA in Tax" and Euromoney's "Best of the Best USA in Transfer Pricing."
Fuller is one of the three "most highly regarded" US tax practitioners according to Who's Who Legal, and is the only US tax adviser to receive a Chambers star performer rating (higher than first tier).
Six Fenwick tax partners have appeared in Euromoney's World's Leading Transfer Pricing Advisors. Eight have appeared in International Tax Review's World's Tax Controversy Leaders.
Fenwick & West LLP has represented 6 of the Fortune Top 10 companies, well over 50 of the Fortune 100 companies, and over 100 of the Fortune 500 companies in federal tax matters.
Fuller and his firm have served as counsel in over 150 large-corporate IRS Appeals proceedings and over 75 federal tax court cases. These include the recent taxpayer victory in Analog Devices v. Commissioner, a case that involved section 482 issues.
International Tax Review named Fenwick & West "Tax Firm of the Year for the San Francisco Area" nine times and "US (or Americas) Tax Litigation Firm of the Year" four times.
Recent US International Tax Developments
The outgoing Obama Administration issued an unusual number of lengthy tax regulations just before and after year end31/03/2017
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