CRA resolved an issue at Appeals relating to management fees for a Silicon Valley client. At issue was the beneficial allocation of expenses and the measurement of stock-based compensation. Rebel Curd successfully argued that the client’s beneficial allocation percentage was the most objective measure and that the client maintained sufficient books and records for the use of the fair value method for the inclusion of stock-based compensation. The case was resolved with zero adjustment.
Significant tax risk to non-US companies created by America First Trade Policy
On his first day in office, President Trump signed two memoranda, the Global Tax Deal and the America First Trade Policy, covering noteworthy international...