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Brazilian attorneys, Francisco Lisboa Moreira and Carolina Silveira Becman of Castro, Barros, Sobral, Gomes, discuuss a Brazilian Federal Revenue Service's opinion on the taxation of amounts paid, credited, used, delivered, or remitted abroad on the acquisition of access and remote use of software as a service (SaaS) . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court's July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .
US Treasury has identified eight tax regulations -- including the section 385 debt-equity regulations, the section 367 regulations affecting foreign goodwill and going concern value, and the section 987 foreign currency regulations -- as qualifying for revision under President Trump's executive order mandating a reduction in . . .
The OECD expects to soon release an important update to its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, tax officials said during a June 26 webinar. Officials also discussed the OECD's coming release of a discussion draft . . .
The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
Robert Stack, former deputy assistant secretary for international tax affairs at the US Treasury, has joined Deloitte, the firm announced June 20. Stack will join as a managing director of Deloitte in its . . .
Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . .
Canada's Department of Finance on June 7 announced in separate releases that it will commence tax treaty negotiations with . . .