Americas

Digital Economy

UN tax committee releases official report on outcome of 21st session: Committee of Experts on International Cooperation in Tax Matters→

December 2, 2020

Americas

France to request EU retaliation if US enacts trade sanctions in response to French digital services tax, Le Marie says: Reuters→

December 2, 2020

Africa

OECD toolkit helps developing country tax administrations satisfy confidentiality and data security requirements for automatic exchange of information with other countries: OECD→

December 2, 2020

Americas

Canada to propose digital tax, extend GST/HST laws to nonresident businesses

December 1, 2020

The Canadian government has announced that it will propose a new tax on multinationals that provide digital services . . .

Africa

Shell releases 2019 country-by-country report disclosing revenue, profits, tax paid in 98 countries: Shell.com→

November 30, 2020

Americas

US and Monaco agree to exchange country-by-country tax reports on large multinationals

November 30, 2020

The US IRS today announced that the US and Monaco have agreed . . .

Americas

OECD reports on BEPS MLI developments for Bahrain, Chile, Indonesia, Russia, Kazakhstan

November 30, 2020

Bahrain has signed and Chile has deposited with the OECD its instrument . . .

Americas

The US and Mexico’s transfer pricing approach for maquiladoras

November 30, 2020

Dr. J. Harold McClure, New York City, notes that the US’s announcement on November 16 that the US and Mexico have again agreed to renew their transfer pricing framework for US multinational enterprises that have maquiladora operations and discusses the appropriate arm’s length transfer pricing policies for maquiladoras . . .

Americas

France cancels suspension of digital service tax collection, sends Facebook, Amazon, other large tech firms tax bills due in December: Reuters→

November 25, 2020

Americas

Janet Yellen is Biden’s choice for treasury secretary: Ben White / Politico→

November 25, 2020

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Americas

A proposed transfer pricing safe harbor for US retailers

November 24, 2020

Dr. Ednaldo Silva of RoyaltyStat, Bethesda, MD, proposes that US state tax authorities allow US retailers to apply a safe harbor that defines the arm’s length operating profit markup based upon a formula . . .

Americas

US IRS prevails in Coca-Cola transfer pricing dispute over intercompany royalties

November 23, 2020

Dr. J. Harold McClure, a New York City economist, discusses the US Tax Court’s November 18 ruling in a transfer pricing dispute between the IRS and Coca-Cola which considered the appropriate evaluation of intercompany royalties . . .

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Africa

OECD proposes revised “minimum standards” for nations on cross-border tax dispute resolution

November 19, 2020

The OECD Secretariat has requested public feedback on proposals designed to strengthen the Action 14 minimum standards on cross-border tax dispute . . .

First Look: US Tax Court rules in favor IRS in Coca-Cola transfer pricing dispute

November 19, 2020

The US Tax Court handed a big win to the IRS on November 18 in a transfer . . .

Americas

Blackrock prevails in UK transfer pricing dispute

November 18, 2020

Liz Hughes and Anthony Crewe, of Grant Thornton UK LLP, discuss a November 3 UK First-tier Tribunal decision in a transfer pricing dispute involving US-headquartered Blackrock investment management group . . .

United States

US IRS releases 2020-21 priority tax guidance plan: US Department of Treasury→

November 18, 2020

Americas

Carol Doran Klein retires from USCIB, Rick Minor takes over as tax lead: USCIB→

November 18, 2020

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Americas

US should amend tax rules providing that foreign funds that originate loans have effectively connected income because the policy if flawed and funds work around the rule anyhow, attorney argues: David S. Miller / Proskauer Rose LLP→

November 17, 2020

Americas

First Look: US and Mexico renew of competent authority agreement on Maquiladoras

November 17, 2020

The US IRS on November 16 announced that the US and Mexico have . . .

Americas

US IRS again corrects final regs (TD 9909) limiting deduction for dividends from foreign corporations: Federal Register→

November 16, 2020

Americas

US IRS invites the public to recommend guidance that should be rescinded, modified, or waived to assist businesses and individuals recover from economic effects of COVID-19 pandemic: Federal Register→

November 16, 2020

Americas

Chip Harter, US Treasury deputy assistant secretary for international tax affairs, to leave his post this month: Bernie Becker / POLITICO→

November 16, 2020

Americas

US IRS corrects final regs limiting deduction for dividends from foreign corporations: Federal Register→

November 13, 2020

Professors assess 14 proposals to tax the “cooperative surplus” of highly digitalized MNEs, say DSTs should be treated as creditable withholding taxes: Allison Christians & Tarcisio Diniz Magalhaes / SSRN→

November 13, 2020

Americas

Uranium transfer pricing and Cameco’s battle with Canada

November 11, 2020

New York City economist, Dr. Harold McClure, notes the Canada Revenue Agency’s recent decision to file an appeal in the Cameco transfer pricing dispute and suggests that prices paid by Cameco’s Swiss affiliate to its Canadian mining affiliate for uranium may not be arm’s length . . .

Americas

US issues final and temporary regs on gain or loss from foreign persons from sale of partnership interests: Federal Register→

November 6, 2020

Americas

Colombia clarifies commodities registration rules for transfer pricing as deadlines approach

November 5, 2020

Laura Pinilla, an Associate at BaseFirma, Colombia, discusses guidance recently released by the Colombian tax office that further clarifies new rules requiring taxpayers subject to the transfer pricing regime to register commodities agreements . . .

Americas

Panama becomes 56th nation to finalize MLI

November 5, 2020

Panama has deposited its instrument of ratification for the . . .

Americas

Canada Revenue appeals long-running transfer pricing dispute loss to Supreme Court

November 3, 2020

The Canada Revenue Agency (CRA) has filed an appeal in the Supreme Court of Canada seeking to overturn its June 26 loss . . .

Americas

US IRS again corrects FDII and GILTI regs: Federal Register→

November 3, 2020

Americas

Peru to exchange tax information on companies and individuals with other nations

November 2, 2020

Yasser Zola, Transfer Pricing Manager at BaseFirma Peru, Lima, notes that according to an October 19 Peru tax authority announcement, Peru will soon begin exchanging tax information with other countries . . . .

Americas

US IRS limits taxpayers’ ability to “telescope” results of MAP and APA negotiations into current tax year, requiring taxpayers to instead amend prior years’ returns: Internal Revenue Service→

October 29, 2020

Americas

Croatia to initiate tax treaty negotiations with the United States

October 28, 2020

Ksenija Cipek, Head of Tax Risk Analysis, Ministry of Finance, Tax Administration, Croatia, discusses the Republic of Croatia’s decision to initiate proceedings to conclude a tax convention with the United States. . . .

Americas

US corrects final FDII and GILTI regs: Federal Register→

October 28, 2020

Americas

Final US regs address absorption of NOL carryovers, carrybacks and update rules on consolidated groups that include life insurance and other companies: Federal Register→

October 27, 2020

Americas

16 business groups urge Mexico to drop proposal to cut non-residents’ internet connection if they fail to comply with new tax registration rules: SIIA→

October 26, 2020

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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