The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
Canada's Federal budget 2017, released today, proposes to amend the Income Tax Act to prevent income from the insurance of Canadian risks from being shifted to a foreign branch of a Canadian life insurer . . .
Hong Kong signed treaties with six countries on March 16 for the automatic exchange of financial account information (AEOI) in tax. . .
See: Steptoe & Johnson.
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about difficulties applying the House GOP's destination-based cash flow proposal to partners and partnerships . . . .
US Senators Bernie Sanders (I-Vt.) and Brian Schatz (D-Hawaii) today introduced a tax bill designed to curtail . . .
Paul L. Caron has been named dean of Pepperdine School of Law, Pepperdine University has . . .
Mindy Herzfeld has joined Ivins, Phillips & Barker's corporate and international tax groups located in Washington DC, the firm . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses President Trump's executive order mandating that for every new regulation issued, two must be removed, noting that it will be very difficult to apply this order to US tax regulations . . .
Singapore's Inland Revenue Authority (IRAS) has announced that a new treaty signed with Uruguay will enter into force on March 14. The tax treaty, signed January 15, 2015, clarifies . . .
See: Steptoe & Johnson
JP Canavan discusses newly released draft instructions to US Form 8975, which include information on early country-by-country reporting for US-parented MNEs and on how to report 'stateless' constituent entities . . . . . .