In practice, there are certain requirements to be aware of when dealing with transfer pricing situations in China and Vietnam.
In the case of a U.S. acquisition of a foreign target, it was oftentimes beneficial to make a Section 338(g) election.
Canada, like the U.S., imposes a thorough set of documentation requirements, and imposes penalties for failure to comply.
Perhaps the most significant difference in approach relates to the way in which contingent liabilities assumed in a business combination are reported.
When a company embarks on an international restructuring, it is extremely important to consider the impact of Section 367.