Americas

Chile government introduces significant changes to tax reform package

July 10, 2019

Francisco Sepúlveda of RGS Abogados, Santiago de Chile, analyzes the latest changes to Chile’s comprehensive tax reform package, which include further regulation regarding digital services, new profit distribution rules, and a new definition of taxable expense . . .

Americas

Google, Facebook, Amazon to testify at US trade hearing on French DST: Reuters→

August 14, 2019

Americas

IRS to resume challenges to treatment of stock-based compensation in cost-sharing arrangements

August 5, 2019

The US IRS will once again examine allocations between group members of employee . . .

Americas

US to retaliate against France in response to digital tax, Trump says

July 26, 2019

President Donald Trump today announced in a tweet that the US will retaliate. . .

Americas

US and Curacao negotiating country-by-country reporting exchange agreement

August 14, 2019

The United States and Curacao are negotiating an agreement . . .

Americas

Industry group to file complaint with EU Commission alleging French digital tax is illegal State aid: Isabel Gottlieb / Bloomberg Tax→

July 30, 2019

Americas

US lawmakers say UK digital tax would hinder post-Brexit trade deal: Colin Wilhelm & Isabel Gottlieb / Bloomberg Tax→

July 17, 2019

Americas

Proposed IRS regs address cloud computing transactions, copyrighted article downloads

August 13, 2019

The US IRS on August 9 issued proposed regulations (REG-130700-14) concerning the income tax . . .

Americas

Brazil’s effort to align its transfer pricing rules with OECD standards

July 17, 2019

Francisco Lisboa Moreira of Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the status of a joint effort of the OECD and Brazil’s tax authority to reduce the gaps between Brazil’s transfer pricing regime and the OECD transfer pricing guidelines ahead of Brazil’s ascension to the OECD . . .

Americas

US IRS provides guidance on section 965 deemed repatriation rules

July 1, 2019

The US IRS on June 27 released questions and answers to assist multinational . . .

Americas

Allergan to move from Ireland back to US because of TCJA rate cut as part of AbbVie acquisition: Sony Kassam / Bloomberg Tax→

June 26, 2019

Americas

US MNEs repatriated USD 876.8 billion since TCJA enacted, data shows: Katia Dmitrieva & Laura Davison / Bloomberg→

June 21, 2019

Americas

US IRS releases priority guidance plan third-quarter update

June 21, 2019

The US IRS on June 17 issued its third-quarter update to its 2019 priority guidance . . .

Americas

US Senate ratifies long-pending tax treaty protocol with Spain

July 17, 2019

The US Senate on July 16 ratified a protocol to the US-Spain tax treaty (Treaty Doc. 113-4), the first US ratification of a tax treaty or tax treaty protocol since 2010. The protocol . . .

Americas

US, Monaco negotiating agreement for exchange of country-by-country reports

July 1, 2019

The US today announced it is negotiating a competent authority agreement . . .

Americas

Uber generated $6.1 b Dutch tax deduction by transferring IP with increased value from a Bermuda sub to Dutch sub controlled by Singapore company: Lynnley Browning & Eric Newcomer / Bloomberg→

August 12, 2019

Americas

Mexican government to propose increased tax on digital economy and e-commerce without adding a DST: Sharay Angulo & Anthony Esposito / Reuters→

August 1, 2019

Americas

Altera files Ninth Circuit petition for rehearing in challenge to US cost-sharing regulations: Steve Dixon / Miller & Chevalier→

July 25, 2019

Americas

House Ways and Means lawmakers urge US response to France’s digital tax proposal

June 20, 2019

US House Ways and Means Committee members . . .

Americas

US-Dominican Republic FATCA agreement enters into force

July 25, 2019

The US Treasury has announced on its website that the US-Dominican Republic Model 1 FATCA intergovernmental . . .

Americas

US announces probe into France’s digital services tax

July 10, 2019

The US will investigate whether France’s digital services tax, expected to pass the Senate . . .

Africa

Switzerland’s Federal Council approves plan to exchange account data with 19 more country tax administration

May 30, 2019

Davide Anghileri of the University of Lausanne writes that Switzerland’s Federal Council adopted a dispatch yesterday approving the introduction of automatic exchange of financial account information with 19 more countries . . .

Africa

Switzerland to exchange financial account information with 33 more countries for tax purposes

August 15, 2019

Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Americas

US MNEs reversing inversions, less likely to invert in the first place, because of 2017 tax changes: Richard Rubin & Jared S. Hopkins / WSJ→

August 1, 2019

Americas

IRS issues final partnership regs on allocation of creditable foreign taxes

July 25, 2019

The US IRS on July 24 published final regulations . . .

Americas

US Senate Foreign Relations Committee approves tax treaty protocols with Japan, Luxembourg, Spain, Switzerland

June 25, 2019

Tax treaty protocols amending US tax treaties with Japan, Luxembourg . . .

American Samoa

Dominica removed from the EU tax blacklist

June 17, 2019

The Council of the EU on June 14 removed Dominica from the . . .

Americas

Newly signed Brazil-Uruguay tax treaty will force companies to review structures

June 13, 2019

Francisco Lisboa Moreira of Bocater, Camargo, Costa e Silva, Rodrigues Advogados discusses the new Brazil–Uruguay tax treaty and protocol, signed June 7 . . .

Americas

US urging market countries to accept only modest changes to international tax system

June 6, 2019

The US is urging countries to agree to new international tax rules that would allocate a limited amount of additional profit and related taxing rights to countries where a multinational’s customers or digital users reside. In exchange for these additional taxing . . .

BVI, Bermuda, Cayman top tax haven list; UAE, UK, France most aggressive in lowering other countries withholding tax via treaty: Tax Justice Network→

May 29, 2019

Americas

US IRS publishes final section 956 regs applicable to US corporate shareholders

May 23, 2019

The US IRS today published final regulations that provide a mechanism to exclude corporations . . .

American Samoa

EU Council revises tax blacklist, plans less frequent list updates

May 17, 2019

Davide Anghileri of the University of Lausanne discusses today’s decisions by the EU Council regarding the EU list of non-cooperative tax jurisdictions . . .

Americas

Corporate veil dropping: British crown dependencies make beneficial ownership registers public, US takes baby steps

June 24, 2019

Virginia La Torre Jeker, J.D., a US tax practitioner located in Dubai, discusses June 19 announcements of Jersey, Guernsey, and the Isle of Man about plans to make beneficial ownership registers for legal entities public and US legislation proposed June 11 in this area . . .

Americas

In letter, US Senators Grassley and Wyden urge Treasury to use “all available tools” including Section 891, to stop France from enacting a DST: US Senate Committee and Finance→

June 24, 2019

Americas

US strikes deal with Mexico, suspends tariffs on Mexican goods: David Jackson / USA Today→

June 10, 2019

Americas

Peru issues new tax guidance on indirect transfers

June 7, 2019

Carlos Vargas Alencastre and Franz Salazar Anccasi of TPC Group Peru, discuss guidance issued June 4 by Peru’s tax administration on the indirect transfer rules, which levy tax on the transfer of shares in a non-Peruvian company that directly or indirectly owns shares in a Peruvian company . . .

Americas

US IRS investigating Uber’s 2013–14 transfer pricing position: Giles Turner / Bloomberg→

June 4, 2019

Americas

Tax laws of 12 low-tax countries including BVI, Bermuda, Cayman don’t harm other countries, 131-country group concludes

July 23, 2019

An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved. . .

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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