parent company and subsidiary

• Playing the Price Is Right Overseas: Foreign Tax Laws Are Complicated

Companies looking to expand internationally will find the tax laws are as complicated and bewildering as foreign languages and customs. Transfer pricing" is a growing concern for multinational companies, since it's receiving increased scrutiny from taxing authorities around the globe. The term refers to rates utilized when selling goods or services between a parent company and a subsidiary, or between divisions or departments of a company.

• Long Island Business News
• January 26, 2011

• Ross Glenn Moorman, Jr., Plaintiff-Appellant, v. Unumprovident Corporation, a Delaware Corporation, in Its Individual Capacity and as Controlling Parent of Its Wholly Owned Subsidiary, Unum Life Insurance Company of America, a Maine Corporation, Unum Life Insurance Company of America, a Maine Corporation, in Its Individual Capacity and as a Wholly Owned and Controlled Subsidiary of Unumprovident Corporation, Unum Corporation, a Maine Corporation Merged To Form Unumprovident Corporation, in Its Individual Capacity and as Controlling Parent Company of Its Wholly Owned Subsidiary, Unum Life Insurance Company of America, a Maine Corporation, Defendants-Appellees., 464 F.3d 1260 (11th Cir. 2006)

Elizabeth J. Bondurant, Kenton Jones Coppage, Nikole Marie Crow, Carter & Ansley, LLP, Atlanta, GA, for Defendants-Appellees. Appeal from the United ...

• Federal Circuits

• The David R. Tillinghast Lecture: Can a Subsidiary Be a Permanent Establishment of Its Foreign Parent?

Tax authorities have the right to recharacterize a subsidiary as a branch if they can demonstrate the subsidiary's excessive dependence. It may even be in their interest to recharacterize the subsidiary as a PE where the implementation of a tax adjustment based on transfer pricing faces procedural problems. For instance, the State Council ruled on November 7, 2005 in the Cap Gemini case that, in order to implement the transfer pricing procedure, the tax authorities must first demonstrate that the benefit granted to the subsidiary by the parent company or by the subsidiary to the parent company, is higher than the benefit that would have been granted lacking any dependence between the two companies involved in similar circumstances. The recharacterization of a subsidiary as a PE, assumin...

• Tax Law Review
• Vol. 60 Nbr. 3, April 2007

• Notice: Ninth Circuit Rule 36-3 Provides that Dispositions Other Than Opinions or Orders Designated for Publication Are Not Precedential and Should Not Be Cited Except When Relevant Under the Doctrines of Law of the Case, Res Judicata, or Collateral Estoppel. City of Fairbanks, a Municipal Corporation of the State of Alaska, Plaintiff-Appellant/Cross-Appellee, v. Amoco Chemical Company, a Corporation, Aka Amoco Chemicals Company, a Successor of and Formerly Known as Amoco Chemicals Corporation, and Amoco Reinforced Plastics Company, a Wholly Owned Subsidiary and Alter Ego of Its Parent Amoco Chemical Company, Defendants-Appellees/Cross-Appellants., 46 F.3d 1139 (9th Cir. 1995)

Before: HUG, HALL, and THOMPSON, Circuit Judges. MEMORANDUM* The City of Fairbanks, Alaska ("City"...

• Federal Circuits

• Mmc to Shuffle Officers

PRESQUE ISLE Officials at Maine & Maritimes Corp. said that coming changes in the company's administration will be key to developing connections to new energy markets within New England. Maine & Maritimes is a subsidiary of Emera Inc. and the parent company of Maine Public Service Co., an electric transmission and distribution utility, which has roughly 36,000 customers in northern Maine.

• Bangor Daily News
• June 07, 2011

• N.Y. Lawsuit Accuses Toshiba of Discrimination

NEW YORK - A human resources manager at a Toshiba America Inc. subsidiary sued the company Monday for $100 million, accusing the electronics giant of discriminating against women. Elaine Cyphers of Mecklenburg County, N.C., brought the lawsuit in U.S. District Court in Manhattan against the parent company and Toshiba America Nuclear Energy Corp., a subsidiary that promotes advanced boiling water nuclear power plants. The lawsuit seeks class- action status on behalf of women who are, or have been, employed by Toshiba in the United States.

• Charleston Daily Mail
• February 02, 2011

• A Time of Transition: Lessons in Global Od From a Successful Japanese Firm

By examining the transition from local to global OD practices within a Japanese firm, critical lessons can be learned regarding the importance of understanding and communicating organizational context, the need to exercise care when selecting global interventions, overcoming some of the common challenges of working across cultures, and the possibility of viewing global organization development as a series of developmental stages. This paper presents several successful early-stage and transitional events aimed at improving organization development efforts and coordination between a well-established Japanese parent company and its US-based subsidiary or branch, which is one of the fastest growing pharmaceutical companies in the US. The company described here is Takeda Pharmaceuticals Co, ...

• Organization Development Journal
• Vol. 25 Nbr. 3, October 2007

• Guilty Plea May Not Hurt Contractor's U.S. Unit ; Bae's Licensing Tied to National Security

The U.S. arm of Europe's largest defense contractor, BAE Systems, is unlikely to be significantly hurt by its guilty plea in a bribery- related probe this month, said officials involved in issuing licenses to the British company. Although the Justice Department fined BAE $400 million, the officials said three other factors will be taken into account when reviewing license applications: the firm's high importance to the Pentagon, its cooperation with the U.S. government and the fact that, unlike the parent company, its U.S. subsidiary was not found guilty of criminal wrongdoing.

• The Washington Times
• March 16, 2010

• First Niagara Finds Board Director with Global Marketing Experience ; New Appointment Breaks Tradition

First Niagara Financial Group said Monday that it had named a new director to its board, adding a former Burger King Corp. and General Mills executive with experience in global marketing and strategy. The Buffalo-based parent of First Niagara Bank appointed Peter B. Robinson to the boards of the company and the bank subsidiary.

• Buffalo News
• February 01, 2011

• Risky Business: China Issues New Rules on Permanent Establishment Risk for Foreign Business in China.

... how PE conditions apply to a foreign company's domestic activities, and gives local tax bureau'... establishing a Chinese-registered subsidiary or representative office. However, even businesses... are separate from those of its foreign parent company. It should not constitute a PE merely beca...

• Mondaq Business Briefing
• Nbr. 2011, January 2011