Transfer Pricing

By Molly Moses

A U.S. Tax Court judge questioned a former Eaton Corp. official Wednesday about the company's decision to restructure the ownership of a valuable foreign subsidiary when it inverted in 2012, noting that the move placed a $14 billion asset out of the U.S. company's reach.

By Josh White

Switzerland has adopted the dispatch on the double taxation agreement with Zimbabwe as part of expanding its tax treaty network in the region, the Swiss government announced Wednesday.

By Natalie Olivo

A U.S. Supreme Court ruling that gutted deference to agencies took center stage in the Eighth Circuit's recent decision that backed 3M's challenge to transfer pricing rules, signaling the strict statutory analysis that courts may now apply to tax regulations.

By Molly Moses

Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.

By Molly Moses

An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."

By Kevin Pinner

Kenya's tax authority invited feedback Monday for draft regulations covering its domestic minimum top-up tax and a separate set of draft regulations for its program to offer advance pricing agreements.