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Americas

Americas

Trump proposes 15 percent corporate tax rate, territorial tax system

April 26, 2017

President Trump on Wednesday unveiled his tax plan, proposing steep reductions in both individual and corporate income tax rates as well as a move to a territorial tax . . .

Americas

Saudi Arabia FATCA IGA signed with US

November 16, 2016

The US Treasury Department has today updated its FATCA website, reporting that Saudi Arabia has signed a Model 1 intergovernmental agreement (IGA) with . . .  

Americas

Isle of Man signs tax information exchange agreement with Turks and Caicos Islands

September 20, 2016

The Isle of Man government has announced this week that it has signed a tax . . .

Americas

Jennifer Molnar rejoins Baker & McKenzie’s international tax practice

September 7, 2016

Jennifer Molnar has rejoined Baker & McKenzie as a partner in the firm’s Washington, DC office. Molnar advises on tax planning for international acquisitions . . .

Americas

New Mexican APA rules allow tax authority site visits: PWC→

August 7, 2016

See: PWC.

Americas

US IRS issues corrections to inversion regulations

June 23, 2016

The US IRS on June 23 issued corrections to final and temporary regulations (TD 9761) published April 8 dealing with inversions . . .

Americas

Panama, Bahrain, Lebanon, Nauru, Vanuatu pledge to combat tax evasion through automatic information exchange

May 11, 2016

Panama was among five countries that this week pledged to share financial account information automatically with other countries, the OECD . . .

Americas

US proposed regs would force shareholders of foreign owned-single member LLCs to reveal their identity, final regs require customer due diligence: White House→

May 6, 2016

See: White House, proposed regulations, press release, Letter by Treasury Secretary Lew.  More: Bloomberg, The Guardian, Wall Street Journal, Economic Times. 

Americas

NGO effort to cast US MNEs as tax dodgers has succeeded, Stack says:  Alex M. Parker / Bloomberg BNA→

March 3, 2016

See: Bloomberg BNA.

Americas

Mexico to tax digital platforms as interim measure, tax official says: Reuters→

April 9, 2019
Africa

Brazil signs tax treaty with UAE potentially ending blacklisting, approves South Africa pact

November 14, 2018

Francisco Lisboa Moreira of Bichara Advogados, São Paulo, discusses the latest tax treaty developments in Brazil . . .

Americas

Colombia tax reform expected to include rate reduction, thin cap change, new rules for financial transactions: EY→

October 29, 2018
Asia-Pacific

US, Austria sign agreement to exchange country-by-country reports on multinationals

August 24, 2018

The US and Austria have signed a competent authority agreement to exchange country-by-country reports on multinationals operating in their countries, US Treasury . . .

Americas

MNEs developing strategies to avoid the US’s new BEAT: Richard Rubin / Wall Street Journal→

June 26, 2018
Americas

New York bill would remove GILTI income from state and local tax computation: Eversheds Sutherland→

June 13, 2018
Americas

US Supreme Court Justices consider South Dakota’s push to collect sales tax from out-of-state online retailers: Bernie Becker / Politico→

April 18, 2018
No Picture
Americas

Bahamas, US Virgin Islands, Saint Kitts to be added to EU tax blacklist, leaked document says

March 9, 2018

The Bahamas, US Virgin Islands, and Saint Kitts and Nevis will be added to the EU’s blacklist of non-cooperative third-country tax havens on March 13 during an EU finance ministers meeting, Reuters has reported, citing a leaked EU document dated March 8. This latest leak follows a widely-reported earlier leak that . . .

Americas

Brazil removes Costa Rica, Madeira, Singapore from tax haven list, but adds regimes to “privileged”list: KPMG→

January 17, 2018
Africa

Bahamas and Zambia join Inclusive Framework on BEPS

December 17, 2017

The Bahamas and Zambia have joined the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), the OECD announced December 14.  The addition of the two nations brings to 110 the total number of countries . . .

Africa

Cayman Islands lobbies EU and UK officials seeking exclusion from tax blacklist: Brent Fuller / Cayman Compass→

November 27, 2017
Americas

US court invalidates “serial inversion” tax regulation that ended Pfizer-Allergen merger

October 10, 2017

Steptoe & Johnson’s Amanda Varma & Brigid Kelly analyze a recent US court decision holding that the IRS’s temporary serial inversion regulations are invalid because the government failed to observe Administrative Procedures Act notice and comment requirements . . .

Americas

Ecuador adds Hong Kong to tax haven blacklist: EY→

August 28, 2017
Americas

Miesel to lead Mazars’s US transfer pricing practice

August 15, 2017

Victor H. Miesel has joined Mazars USA as a partner, national transfer pricing practice leader, and chief economist, Mazars announced . . .

Americas

Argentina suspends new rules for taxing nonresident capital gains: KPMG→

August 3, 2017
Americas

US to repeal or revise debt-equity regulations, other tax guidance, under Trump order

July 9, 2017

US Treasury has identified eight tax regulations — including the section 385 debt-equity regulations, the section 367 regulations affecting foreign goodwill and going concern value, and the section 987 foreign currency regulations — as qualifying for revision under President Trump’s executive order mandating a reduction in . . .

Americas

Trump won’t back border adjustment tax, sources say: Kate Kelly, Rachel Abrams, Alan Rappeport: The New York Times→

April 25, 2017
Americas

Kautter to be appointed US assistant secretary for tax policy, sources say

April 4, 2017

The Trump administration has selected David Kautter as the next US assistant secretary for tax policy, a post critical for moving forward the US tax reform agenda, Poltico has Poltico has reported. Kautter, a partner and leader . . .

Americas

US, ​Saudi Arabia FATCA agreement enters into force

March 29, 2017

The US Treasury Department has updated its FATCA website, reporting that a Model 1 intergovernmental. . .

Americas

British Virgin Islands set to join OECD Inclusive Framework on BEPS

December 19, 2016

The British Virgin Islands will join the OECD/G20 Inclusive Framework, pledging to adopt and work toward the implementation of the minimum international tax standards in the OECD/G20 Base Erosion Profit Shifting . . . 

Americas

Isle of Man tax information exchange agreements with BVI, Cayman Islands, and Romania enter into force

September 20, 2016

The Isle of Man government announced this week that three tax information exchange agreements signed with other nations. . .

Americas

Kadet & Koontz offer objective ethical framework to test MNE profit shifting structures: SSRN→

August 7, 2016

See: Profit-Shifting Structures: Making Ethical Judgments Objectively, by Jeffery M. Kadet, David L. Koontz, SSRN. Part one, Part two.

Americas

Former US Treasury officials dispute proposed tax regulations combating inversions 

April 18, 2016

A group of 18 former US Treasury Department officials today sent a letter to Treasury Secretary Jacob J. Lew, urging the government to reconsider recently issued tax regulations aimed at stopping US companies . . .

Americas

“Marketing intangibles” solution to global digital tax dispute should apply only to consumer-facing businesses, US official says

February 19, 2019

A US-backed proposal for globally coordinated rules allowing market countries to tax a greater share of multinational firm profits based on “marketing intangibles” should be limited to businesses that ultimately sell to . . .

Americas

US adds many new international tax projects to priority guidance list

November 8, 2018

The US Treasury and IRS today released its 2018–2019 Priority Guidance Plan, detailing tax guidance the government . . .

Americas

Canadian Tax Court rules income from grocery firm Loblaw’s Barbadian banking subsidiary was taxable foreign accrual property income: BNN Bloomberg→

September 10, 2018
Americas

Japan to negotiate tax treaty with Ecuador

August 24, 2018

Japan’s Ministry of Finance today announced that Japan and Ecuador will enter into . . .

Americas

New IRS manual aims to guide audit personnel in transfer pricing examination process

July 17, 2018

Marc M. Levey, a partner in Baker McKenzie’s New York office, discusses a new IRS manual designed for IRS agents called the Transfer Pricing Examination Process which may also be a helpful tool for taxpayers preparing for transfer pricing examinations . . .

Americas

Indonesia waives local tax filing requirement for US-parented multinationals

April 28, 2018

Indonesia will not impose local filing obligations on constituent entities of US multinational groups tax resident in Indonesia respect to fiscal years commencing on or after January 1, 2016, even if the US and Indonesia do not reach a competent . . .

Americas

IRS attorney-advisor Ryan Kelly joins Alston & Bird

April 6, 2018

Ryan J. Kelly has joined Alston & Bird’s Washington, DC federal and international tax group as . . .

Posts navigation

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What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
RECENT COMMENTS
  • 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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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • 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

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.