Business restructurings achieve economic benefits through a broad array of strategies. Cost savings and operational improvements are often key drivers. The primary mechanisms used to achieve the company's goals involve the redeployment of functions, assets or risks. Therefore, a restructuring exercise may offer significant tax planning opportunities through transfer pricing.

he Internal Revenue Code is notorious for complicated rules, confusing provisions and differing interpretations of its most simple provisions. For example, the global interest netting provision in Section 6621(d) enacted in 1998 was recently subject to the same confusion that plagues so many other sections.

Between talk about the "fiscal cliff" and budget shortfalls, it is clear that Congress must act to move towards a balanced budget and reduce deficits.

Previous issues of Tax Advisor Weekly have highlighted not only the 2009 Union Carbide ("UCC") memorandum decision by the Tax Court, but also the subsequent Second Circuit Court of Appeals hearing in New York City on March 29, 2012.