The US IRS today announced that it will modify tax regulations under section 367 to address triangular reorganizations involving foreign corporations . . .
Alex Cobham will take over as executive director of the Tax Justice Network, the advocacy group . . .
A proposed directive for an EU common corporate tax base (CCTB), to be presented by the EU Commission next week, and the EU’s planned common consolidated corporate tax base (CCCTB) proposal, would be mandatory for multinational groups operating in the EU that have annual revenue exceeding €750 million . . .
Hong Kong’s tax authority today announced that a tax treaty between Hong Kong and Korea entered . . .
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss newly issued Notice 2016-52, targeting tax planning undertaken by US multinationals that anticipate large foreign-initiated tax adjustments, noting that the guidance is not limited to adjustments under EU state aid law . . .
Pakistan today became the 104th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the . . .
Liechtenstein has been placed on Italy’s national tax “white list,” Liechtenstein’s. . .
Former Chief of Staff of the Joint Committee on Taxation, Hank Gutman, has joined Ivins, Phillips & Barker, Washington, where he will lead firm’s federal tax policy . . .
Beginning in 2017, the US will stop treating a country as if it has FATCA intergovernmental agreement (IGA) “in effect” if the country does not adequately prove that it has a plan . . .
The Hong Kong government on June 3 gazetted Inland Revenue (Amendment) (No. 2) Ordinance 2016, which provides a concessionary profits tax rate of 8.25 percent for qualifying corporate treasury centers and more generous rules for . . .
Countries participating in the OECD/G20 base erosion profit shifting (BEPS) project sought to rewrite international tax rules for the digital economy and for intellectual property to increase their tax take at the expense of the United States, Robert Stack, Treasury deputy assistant secretary. . .
The EU Parliament’s Economic and Monetary Affairs Committee on Tuesday approved a report proposing to give the EU Commission full access to country-by-country reports of multinationals that are . . .
Professor Masao Yoshimura of Hitotsubashi University provides an overview of the corporate tax and transfer pricing changes in Japan’s tax reform 2016, enacted on March 29. . .
See: GAARs and Treaties. From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6? by Andrés Báez. Available at: SSRN
Konstantin Sakuth of Linklaters LLP, Munich, provides an update of Germany and France’s plan to jointly develop a common corporate tax base for Europe, noting June 5 comments made by Germany’s Martin Kreienbaum at the OECD Tax Conference in Washington and a May 31 German government announcement on the topic . . .
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