Americas

Grenada joins “Inclusive Framework on BEPS” to fight multinational group tax avoidance

October 26, 2018

Grenada has joined the “Inclusive Framework on BEPS,” becoming the . . .

Americas

What Brazil’s coming elections mean for tax and transfer pricing

October 19, 2018

Francisco Lisboa Moreira of Bichara Advogados, São Paulo discusses likely tax and transfer pricing changes in Brazil following presidential elections on October 28. . .

Americas

US Democrats call TCJA international provisions a loophole-ridden “mess” that encourages overseas investment: US Senate Committee on Finance→

July 25, 2018

Apple pays Ireland 1.5 billion euros (USD 1.76 billion) in escrow toward 13 billion tax bill in State aid dispute: Reuters→

May 22, 2018

Americas

IRS clarifies withholding tax rules for dispositions of partnership interests by foreigners

April 2, 2018

The US IRS today issued new guidance on the withholding tax on dispositions by nonresident aliens or foreign corporations of partnership interests that . . .

Americas

Brazil seeking to align transfer pricing regime with OECD norms

March 5, 2018

Francisco Lisboa Moreira of Bichara Advogados, São Paulo, discusses a joint project undertaken by Brazilian and OECD tax officials to more closely align Brazil’s international tax and transfer pricing regime with OECD guidelines, noting this project could result in changes to Brazil’s fixed margin and royalty deduction rules . . .

Americas

UK says US-based MNEs underpaid GPB 4.6 billion (USD 5.9 billion) of UK tax last year: Out-law.com→

April 24, 2019

Americas

US issues technical corrections to final Section 965 regs on transition tax: Federal Register→

April 10, 2019

Americas

Draft US accounting standards update would require income tax disclosures to be disaggregated between federal, state, foreign: Financial Accounting Standards Board→

March 27, 2019

Americas

IRS announces extension of private letter ruling program for corporate stock distributions: Internal Revenue Service→

March 13, 2019

Americas

US FDII rules under review as potentially harmful tax regime, Treasury official says

February 19, 2019

The US’s foreign-derived intangibles income (FDII) tax rules are being scrutinized by the OECD’s Forum on Harmful Tax. . .

Americas

Outgoing US House GOP releases draft TCJA technical corrections: US Ways and Means→

January 2, 2019

Today, House Ways and Means Committee Chairman . . .

More: Discussion draft, JCT technical explanation.

Americas

Manal Corwin to lead KPMG’s Washington tax practice

November 14, 2018

Manal S. Corwin has been named principal-in-charge of KPMG’s . . .

Americas

China to immediately impose tariffs on 128 US products: Damian Paletta / The Washington Post→

April 2, 2018

Americas

US IRS releases frequently-asked-questions on new tax law’s deemed repatriation of foreign earnings

March 13, 2018

The US IRS today released frequently-asked-questions designed to help taxpayers meet the filing and payment obligations of the section 965 transition . . ,

Americas

Goodbye to All That?: A Requiem for the Destination-Based Cash Flow Tax: Daniel Shaviro / SSRN→

February 19, 2018

Americas

Brazilian guidance addresses taxation of cross-border software licensing payments

May 7, 2019

Francisco Lisboa Moreira, a partner with Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the Brazilian Federal Revenue’s April 15 guidance addressing the taxation of cross-border software licensing for commercialization or distribution . . .

Americas

India, US sign agreement for exchange of country-by-country reports: Hindu Business Line→

March 27, 2019

Americas

France’s new digital tax could spur US countermeasures, lawmaker says: Kevin Brady / US House of Representatives→

March 6, 2019

Africa

IMF paper concludes African countries worse off for signing tax treaties with “investment hubs” like Mauritius

October 26, 2018

African countries that signed tax treaties with Mauritius and other nations considered to be “investment hubs” did . . .

Americas

US IRS proposes to withdraw controversial Section 385 debt-equity documentation regulations

September 23, 2018

The US IRS on September 21 proposed to revoke the hotly contested Section 385 debt-equity documentation regulations and work toward developing . . .

Americas

OECD, EU require Barbados to remove ring-fenced international tax regimes by December 31, Prime Minister says: Katrina King / Barbados Today→

August 27, 2018

Americas

UK reverses support for EU interim digital tax fearing US retaliation, sources say: Bjarke Smith-Meyer / Politico→

April 29, 2018

Americas

IRS signed 116 advance pricing agreements in 2017

March 30, 2018

The US IRS today released statistics on the performance of its advance pricing agreement (APA) program in 2017, revealing that the tax agency signed 116 APAs that year. APA are agreements signed between the tax agency and multinational taxpayer resolving transfer pricing . .

Americas

Cayman Islands issues notice on country-by-country reporting for multinationals

February 9, 2018

The Cayman Island government on February 2 published an advisory for multinational corporations on country-by-country reporting in advance of the release of planned guidance on the topic. The government . . .

Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

United States

US corps have repatriated fewer foreign profits than expected post-tax reform, blame foreign taxes: Laura Davison / Bloomberg→

December 7, 2018

The amount of offshore cash U.S. corporations have returned home so far this year . . .

More: ITEP, The Mercury News.

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Americas

US IRS to amend country-by-country reporting regulations to protect national security

March 30, 2018

The US IRS today announced that it will amend its guidance for large multinationals on country-by-country reporting obligations to prevent reporting that jeopardizes national . . .

Americas

US advance pricing agreement applications surged in 2018, data shows

March 27, 2019

The US IRS today issued its annual report providing statistics on its advance pricing agreement (APA) program. The data reveals a . . .

Americas

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

February 19, 2019

The OECD today asked multinational taxpayers and their advisors to provide information about their experiences with the tax treaty . . .

Americas

Facebook’s trial in $5 billion US transfer pricing dispute extended to Feb. 2020: Sony Kassam / Bloomberg Tax→

January 4, 2019

Americas

US Treasury Secretary Mnuchin decries “unilateral and unfair” digital tax proposals

October 25, 2018

US Treasury Secretary Steven Mnuchin today issued a statement condemning proposals being floated in the EU and elsewhere . . .

Americas

Despite US tax reform, companies still moving IP abroad: Laura Davison / Bloomberg→

October 16, 2018

Canada

What the UK’s new transfer pricing and diverted profits tax statistics tell us

August 1, 2018

Liz Hughes, a partner with Grant Thornton UK LLP, discusses the UK’s 2017–18 transfer pricing and diverted profits tax statistics, released July 31, noting several interesting trends . . .

Americas

US IRS again delays foreign currency tax regs

June 13, 2018

The US IRS today announced that it will further extend the due date of section 987 final and temporary regulations dealing with the taxation of foreign currency gains and losses. The regulations were originally published . . .

US can’t intervene in Apple’s European tax dispute, EU’s top court rules

May 21, 2018

The Court of Justice of the European Union (CJEU) has ruled that the United States may not intervene in the Apple state aid case, thus . . .

Americas

Morgan Lewis nabs three more Baker McKenzie tax pros

February 5, 2018

Morgan Lewis today announced the expansion of its Chicago tax team, adding three new partners: Joshua Richardson, Adam Beckerink, and Michael Liu. Richardson, Beckerink, and Liu are formerly with Baker McKenzie. They join Tom Linguanti . . .

Americas

Brazilian tax authority rules cross-border payment for software as a service (SaaS) subject to withholding

July 19, 2017

Brazilian attorneys, Francisco Lisboa Moreira and Carolina Silveira Becman of Castro, Barros, Sobral, Gomes, discuuss a Brazilian Federal Revenue Service’s opinion on the taxation of amounts paid, credited, used, delivered, or remitted abroad on the acquisition of access and remote use of software as a service (SaaS) . . .

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

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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