Sullivan & Cromwell LLP

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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...

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...

German Merger Control: German Federal Cartel Office Imposes Landmark Fine on Individual for Incomplete Notification of a Merger
Axel Beckmerhagen,Juan A. Rodriguez, January 28, 2013
On 15 January 2013, the German Federal Cartel Office imposed a fine of €90,000 on the high profile German businessman Mr. Clemens Tönnies for providing incomplete information in the merger notification by Tönnies Holding GmbH & Co. KG, a company controlled by Mr. Tönnies,...

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