Americas

Asia-Pacific

US trade report says India’s equalisation levy impedes trade, risks retaliation: Kirtika Suneja / The Economic Times→

April 29, 2020

Americas

Former IRS APMA Director Dick McAlonan Joins Alvarez & Marsal Taxand’s Washington DC office: Alvarez & Marsal Taxand→

April 29, 2020

Africa

COVID-19 and the future of Pillar one

April 22, 2020

Oliver Treidler, CEO, TP&C GmbH, Berlin, considers how the COVID-19 crisis will likely affect global negotiations to reform the taxation of multinational groups, noting that a delay could give transfer pricing practitioners time to formulate an alternative, updated, concept of value creation to replace Pillar one’s formulaic elements . . .

Americas

US IRS issues guidance on COVID-19 travel disruptions’ effect on tax residency, treaty benefits, foreign earned income exclusion

April 22, 2020

The US IRS on April 21 issued tax guidance explaining how the IRS will view an individual’s unexpected travel disruptions due to the COVID-19 emergency for purposes . . .

Africa

Denmark denies coronavirus aid to companies registered in countries on EU list of noncooperative tax jurisdictions: Nikolaj Skydsgaard / Reuters→

April 21, 2020

Africa

US tax policy nonprofit tracks worldwide COVID-19 tax relief: Tax Foundation→

April 17, 2020

Americas

US IRS reconsidering ruling limiting foreign tax credit carryback

April 17, 2020

The US IRS today announced that it has suspended Rev. Rul. 71-533, 1971-2 C.B. 413 which concerns. . .

US IRS issues frequently asked questions on transfer pricing documentation, best practices

April 17, 2020

Elisa Kaminsky of BaseFirma, Miami, discusses IRS frequently asked questions, issued April 15, that aim to provide practitioners with best practices regarding transfer pricing documentation . . .

Americas

US IRS signed more advance pricing agreements in 2019 than in recent years but backlog remains

April 15, 2020

The US IRS entered into 120 advance pricing agreements (APAs) in 2019, increasing its annual output as compared to the previous five years, IRS statistics . . .

Africa

Transfer pricing issues arising from the COVID-19 pandemic

April 14, 2020

Gaurav Jain, an India chartered accountant, and Priya Mani Bhutani, a New Delhi transfer pricing professional, discuss the impact of the COVID-19 crisis on transfer pricing . . .

Americas

US IRS Rev. Proc. addresses how to file CARES Act elections for NOL carryback, carryforward: US Treasury→

April 13, 2020

Americas

US IRS exends time to file application for tentative carryback adjustment for NOLs: US Treasury→

April 13, 2020

Africa

OECD issues welcome guidance on tax treaty issues arising from the COVID‑19 crisis

April 13, 2020

Jian‑Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi of DLA Piper Nederland N.V., Amsterdam, discuss April 3 guidance released by the OECD Secretariat addressing how governments should apply standard tax treaty provisions when multinational group taxpayers or their employees are forced to change their behavior to comply with COVID‑19 travel restrictions and quarantines . . .

Americas

First Look: US IRS publishes final and proposed regulations on hybrid mismatches

April 8, 2020

The US IRS today published final (T.D. 9896) and proposed (REG-106013-19) regulations on hybrid arrangements. Hybrid . . .

Americas

US IRS updates web page providing an overview of the MAP process: Internal Revenue Service→

April 2, 2020

Americas

OECD should pause digital tax negotiations, US business group says

March 31, 2020

In a letter to Treasury Secretary Steven Mnuchin, the United States Council for . . .

Americas

US issues final tax regulations on covered asset acquisitions

March 25, 2020

US Treasury and IRS on March 23 released the final version of tax regulations under section 901(m) that

Americas

US extends tax filing and payment deadline for individuals and businesses to July 15: @stevenmnuchin1 / Twitter→

March 20, 2020

Americas

US passes COVID-19 relief law which includes tax credits for paid sick, family, medical leave: Congress.gov→

March 20, 2020

Americas

Jamaica offers tax credits as fiscal stimulus response to the COVID-19: Jamacia Ministry of Finance & Public Service→

March 20, 2020

Americas

Canada defers payment of income tax for businesses, defers SME audits, in response to COVID-19: Government of Canada→

March 20, 2020

Americas

Responding to COVID-19 pandemic, US postpones income tax payment due date to July 15 for up to 1 million in tax, filing due date unchanged: Internal Revenue Service→

March 18, 2020

Americas

US releases 2nd quarter update to priority tax guidance plan: US Department of Treasury→

March 16, 2020

Africa

OECD releases 79 public comments responding to review of country-by-country reporting scheme

March 9, 2020

The OECD today released 79 comment letters it received in response to its consultation on a 2020 review of the country-by-country reporting rules . . .

Americas

Maryland Senate passes digital advertising tax bill: James M. Cain, Ben Marzouk / Eversheds Sutherland→

March 9, 2020

Americas

Maryland’s proposed digital advertising tax draws criticism at hearing: Eversheds Sutherland→

March 5, 2020

Americas

UK to consider US opposition to its planned digital services tax as it negotiates US trade deal: Reuters→

March 2, 2020

Americas

Japan’s finance minister criticizes US digital tax safe harbor proposal at G20 meeting: Leika Kihara / Reuters→

February 26, 2020

Americas

CRS study identifies problems with 2017 US international tax changes, suggests possible revisions: Congressional Research Service→

February 25, 2020

Americas

British Virgin Islands tax authorities to accept country-by-country reporting

February 24, 2020

The British Virgin Islands International Tax Authority (ITA) today announced that it will soon . . .

Americas

OECD releases reports assessing tax dispute resolution in Brunei Darussalam, Curaçao, Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia: OECD→

February 24, 2020

Americas

US makes corrections to final BEAT regs: US Treasury→

February 19, 2020

Africa

Extending transfer pricing benchmarking’s geographic scope: some thoughts on the TPED study

February 18, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, comments on a December study published by the Transfer Pricing Economists for Development (TPED) that presents a new framework for selecting and adjusting foreign comparables . . .

Africa

EU blacklist: Cayman Islands added with other three jurisdictions

February 18, 2020

Davide Anghileri, a researcher at the University of Lausanne, writes that during today’s meeting, the EU Council added four countries to the EU list of non-cooperative jurisdictions for tax purposes and removed 16 countries from the gray list . . .

Americas

Impact of global tax reform effort remains unclear, senior congressional staff members say

February 18, 2020

It is unknown whether the proposed update the international system for taxing multinationals, advanced by the OECD, will benefit or harm US interests, senior staff to Congress’ tax-writing committees said at Tax Council Policy Institue conference, held in Washington DC . . .

Americas

US corrects date in final regs on transfers of property by US persons to partnerships with related foreign partners: US Treasury→

February 17, 2020

Zuckerberg to tell German conference he supports OECD-led tax reform effort depsite likelihood Facebook will pay more tax: BBC News→

February 14, 2020

Africa

First look: OECD publishes transfer pricing guidance on financial transactions

February 11, 2020

The OECD today published its long-awaited transfer pricing guidance on financial transactions, notes Melanie Beirens, Senior Consultant, Zanders, Belgium . . .

Americas

Altera appeals its loss in transfer pricing/stock-based compensation dispute to Supreme Court: Aysha Bagchi / BloombergTax→

February 11, 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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin