Sullivan & Cromwell LLP

IRS Seeks Comments on Bilateral Transfer Pricing Safe Harbor: IRS Seeks Public Comments Regarding the Development of a Model Memorandum of Understanding Between U.S. Tax Treaty Partners Outlining Transfer Pricing Safe Harbors for Routine Distribution Services
James R. Gadwood,Donald L. Korb,Alan D. Kravitz,Andrew P. Solomon,S. Eric Wang, March 21, 2013
On March 15, 2013, the Internal Revenue Service announced that it is seeking comments from the public regarding the development of a model memorandum of understanding between Competent Authorities relating to transfer pricing safe harbors for routine distribution functions. The IRS’s...

Recent Developments Regarding Entity Classification for UK Tax Purposes: HMRC v. Anson - is a Delaware LLC “tax-transparent”?
Emma Hardwick,Michael T. McGowan,Andrew Thomson, March 14, 2013
Whether a non-UK entity such as a Delaware limited liability company (“LLC”) is treated as transparent or opaque for UK tax purposes can make a significant difference to the amount and timing of tax incurred by a UK taxpayer investing in it. The UK Court of Appeal recently upheld the...

Protocol to Japan-U.S. Tax Treaty: Japan and the United States Sign a Protocol Amending the Existing Japan-U.S. Income Tax Treaty
Guy Inbar,Andrew P. Solomon,S. Eric Wang, February 4, 2013
On January 24, 2013, Japan and the United States signed a protocol, together with an exchange of notes related thereto, (the “Protocol”), amending the income tax treaty signed by the two countries in 2003 (as modified by a protocol and exchange of notes signed at the same time, the...

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