In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
Cross Border Transactions
Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.
This article presents some of the transfer-pricing considerations that blockchain companies must address as they grow and expand across borders.