Americas

Americas

AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics

Dr. Harold McClure, a New York City economist, discusses key transfer pricing issues in the Tax Court of Canada’s August 27 ruling in AgraCity Ltd. v. the Queen, including issues involving co-distribution and the appropriate benchmarking for a logistics affiliate . . .

Americas

US IRS to issue S corporation regs reflecting international tax changes

The US IRS on Tuesday announced in Notice 2020-69 that it intends to issue tax regulations . . .

Africa

Taxing somewhere, no matter where: what is the GLoBE proposal really about

Dr. Leopoldo Parada a lecturer at the University of Leeds School of Law, UK, makes the case for rejecting the global anti-base erosion proposal, also known as “GloBE,” introduced into the international tax debate by the OECD . . .

Americas

Economist calls on UN development agency to oppose EU tax blacklisting of Barbados and other small states, calling the action “blatantly discriminatory” policy: Marlon Madden / Barbados Today→

Americas

US congressional staff reviews worldwide digital services taxes and US Section 301 trade investigations: Congressional Research Service→

Americas

First look: US IRS issues final BEAT regulations

The US IRS today released final regulations on the base erosion and anti-abuse tax . . .

Americas

First look: AgraCity and Saskatchewan Ltd. prevail in Canada transfer pricing dispute

The Tax Court of Canada, on August 27, ruled in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd., in a dispute with the Canadian Revenue Agency over . . .

Americas

GAO concludes that US businesses use offshore micro-captive insurance companies to improperly claim tax deductions: US Government Accountability Office→

August 31, 2020

Americas

US IRS now accepting applicants for 2021 Compliance Assurance Process program, allowing large publicly traded corps real-time tax issue resolution: Internal Revenue Service→

August 27, 2020

Americas

New Brazil digital services tax law under discussion

August 26, 2020

Francisco Lisboa Moreira, a Tax Partner at Bocater Advogados, São Paulo, Brazil, and Doris Canen, an International Tax LLM at Kings College/UK, São Paulo, Brazil, write about a Brazil bill, submitted August 18, which proposes to tax large tech companies on gross income derived from digital services provided to Brazilian customers . . .

Americas

Covid-19 has accelerated foreign governments’ need to collect tax revenue from digital giants and the risk of US-led trade war: Vijay Govindarajan, Anup Srivastava , Hussein Warsame, & Luminita Enache / Harvard Business Review→

August 25, 2020

Americas

India’s Google tax contributes 1% of direct tax in IT hubs of Bengaluru and Hyderabad despite expansion to online e-commerce: Shrimi Choudhary / Business Standard News→

August 25, 2020

Africa

The revised operating lease accounting standards: what are the implications for transfer pricing?

Dr. Harold McClure, a New York City economist, discusses how recently revised accounting standards for entities with leased assets impact the financial metrics often used in transfer pricing . . .

Americas

Colombian tax office launches new platform allowing registration of commodities agreements for transfer pricing purposes

Laura Pinilla, an associate with BaseFirma Colombia, discusses a form released August 3 by the Colombian tax office, which is part of a new platform requiring taxpayers subject to the transfer pricing regime to register agreements related to transactions that involve commodities . . .

Americas

US publishes final regs on dividends received deduction limits, proposes regs on extraordinary distributions and GILTI

The US IRS and Treasury on August 21 published final regulations (T.D. 9909) on limitations . . .

Americas

Colombia publishes guidance on taxation of indirect transfers