Americas

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Americas

US IRS releases proposed PFIC regs, withdraws 2015 regs on insurance exception

July 10, 2019

The US IRS today released proposed regulations under sections . . .

Americas

Japan, Argentina sign tax treaty

June 30, 2019

Japan’s Ministry of Finance on June 27 announced . . .

Americas

US Senate to consider Chile, Hungary, Poland, Japan, Luxembourg, Switzerland tax treaty protocols: Bloomberg Tax→

June 18, 2019

Americas

Argentina offers new tax incentives for high tech businesses

June 17, 2019

Sandra Diaz a partner at Basa Firma, writes about Argentina tax incentives, enacted June 6, designed to encourage high technology businesses to locate there . . .

Americas

First Look: US IRS issues final GILTI regulations, proposed DRD regs

June 16, 2019

The US IRS on June 14 released final and proposed regulations on the global intangible low-taxed income (GILTI) regime of section 951A, a key part of the 2018 Tax Cuts and Jobs Act. . .

Americas

Rand Paul to introduce amendments to four tax treaty protocols under US Senate consideration: Isabel Gottlieb & Kaustuv Basu / Bloomberg Tax→

June 24, 2019

Americas

New Peru transfer pricing guidance addresses related-party share transfers

May 23, 2019

Carlos Vargas Alencastre and Franz Salazar Anccasi of TPC Group, Lima, Peru, discuss new Peruvian transfer pricing guidance released May 16 . . .

Americas

US IRS corrects section 987 foreign currency regs

July 1, 2019

The US IRS today made corrections to final . . .

Americas

France seeks to reach digital tax deal with US at August G7 meeting, French minister says: The Local→

July 29, 2019

Americas

White House weighs indexing capital gains to inflation through executive order or rule change, sources say: Saleha Mohsin / Bloomberg→

June 27, 2019

Americas

First look: Altera reversed on appeal, US cost sharing regs are valid

June 9, 2019

The United States Court of Appeals for the Ninth Circuit on Friday reversed the Tax Court’s decision in Altera, finding that . . .

Americas

US IRS large business unit to identify audit targets using data analytics

May 16, 2019

The US IRS today announced that its Large Business & International (LB&I) division will begin making . . .

Americas

Bermuda, Aruba, Barbados set to be removed from EU tax blacklist, EU official says: Reuters→

May 13, 2019

Americas

US IRS notes updates to country-by-country reporting instructions

July 10, 2019

The US IRS today notified taxpayers that that updated . . .

Americas

Canada ratifies BEPS MLI to fight tax avoidance by multinationals

June 24, 2019

Canada has ratified a multilateral tax treaty developed by more than 100 countries that is designed . . .

Americas

US IRS large business unit withdraws cost sharing arrangement directive

June 12, 2019

The US IRS’s Large Business and International Division in a notice published June 4, but dated and effective May 21, has announced . . .

Americas

American Bar Association tax section comments on proposed BEAT regulations→

May 16, 2019

Americas

USCIB worries that UN Practical Manual’s discussion of capital structures in new financial transactions appendix will lead to inappropriate recharacterization of debt vs equity: William J. Sample / USCIB→

July 22, 2019

Americas

Agreement reached on OECD transfer pricing guidelines for financial transactions, official says

June 8, 2019

Countries working on new OECD transfer pricing guidelines for financial transactions have reached agreement on virtually all issues associated with the project, The OECD’s Thomas Balco said June 4 at the 2019 OECD International Tax Conference. Balco also provided an update on other OECD transfer pricing projects, including the 2020 review of the country-by-country . . .

Americas

Proposed US tax regulations address real property exception for foreign pension funds

June 6, 2019

The US IRS today released proposed regulations (REG-109826-17) on the . . .

Americas

US to impose tariffs on all Mexican goods beginning July 1 unless Mexico assists in curbing illegal immigration: Steve Holland & Frank Jack Daniel / Reuters→

May 31, 2019

Americas

Cayman Island guidance released on economic substance

May 16, 2019

The Cayman Islands government on April 30 . . .

Americas

French Senate passes digital service tax despite US threat of potential retaliation, bill likely signed by Macron within two weeks: Liz Alderman / The New York Times→

July 11, 2019

Americas

OECD releases transfer pricing country profiles for Chile, Finland, Italy; updates Colombia, Israel profiles

June 18, 2019

The OECD today released new transfer pricing country profiles for . . .

Americas

Argentina modifies transfer pricing regime

May 29, 2019

Sandra Diaz, a partner with Basa Firma, discusses changes to Argentina’s transfer pricing requirements published on May 27 . . .

Americas

US IRS releases final foreign currency regulations

May 14, 2019

The US IRS on May 13 published final tax regulations applicable to multinationals . . .

Africa

OECD seeks input on tax dispute resolution in Andorra, Anguilla, Bahamas, Bermuda, BVI, Cayman, Faroe Islands, Macau, Morocco, Tunisia

July 17, 2019

The OECD on July 5 requested taxpayer feedback on the tax treaty dispute . . .

Americas

France should renegotiate FATCA unless US agrees to concessions aiding dual nationals, parliamentary report says: Gregory Viscusi / Bloomberg→

May 16, 2019

Americas

Peru clarifies general anti-avoidance rule for cross-border transactions

May 8, 2019

Franz Salazar Anccasi of TPC Group, Peru, discusses important changes to Peru’s general anti-avoidance rule published on May 6 . . .

Americas

US proposed regs address withholding, reporting for partnerships with foreign partners

May 8, 2019

The US IRS on May 7 published proposed tax regulations (REG-105476-18) applicable to . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Americas

Canada speeding up completion time for advance pricing agreements, report shows

August 6, 2018

Kabir Jamal of Goodmans LLP, Toronto, discusses Canada’s 2017 advance pricing agreement report, which reveals improvements in the operation of this government program designed to provide multinational taxpayers with certainty regarding their prospective transfer pricing transactions . . .

Americas

IRS guidance addresses new tax law’s limits on business interest deductions

April 2, 2018

The US IRS today issued guidance on the new cap on large businesses’ interest deductions, enacted in the Tax Cuts and Jobs Act in December 2017. The new rules . . .

Americas

Dominican Republic tax authorities requesting documentation to verify transfer pricing, loans: KPMG→

March 19, 2018

Americas

US tax act’s amendments to CFC stock attribution rules change treatment of US private companies with foreign investment: EY→

February 6, 2018

Americas

First Look: US IRS releases proposed FDII regulations

March 5, 2019

The US IRS on March 4 released proposed foreign-derived intangible income or FDII regulations. The FDII provisions, added in the 2017 Tax Cuts . . .

Americas

St Lucia expected to pass law amending harmful tax regime to avoid placement on EU tax blacklist: Melanius lphonse / Caribbean News Now→

December 11, 2018

Americas

China faces US, Hong Kong pressure to relax plan to tax worldwide income of individuals residing 183+ days there: Jane Cai / South China Morning Post→

November 5, 2018

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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