Medtronic PLC, a medical device manufacturer who used to have operations in Puerto Rico, has defeated the IRS in US Tax Court, resolving a $1.4 billion dispute. The key issue in the case centered on transfer pricing - transactions between different divisions or companies owned by the same corporation or...
International or Foreign Trusts May Cause More Problems Than They Solve
We have seen several recent examples of people who were convinced to set up international or foreign trusts in order to "shield income and assets" from needless taxation. No, these aren't foreign citizens with foreign interests, they are US taxpayers who have been convinced to open a foreign trust which...