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Americas

Americas

IRS announces issue-based campaign to increase tax compliance of large companies, international business

February 1, 2017

The US IRS has announced that it has selected 13 tax and transfer pricing topics that it will focus on in an issue-based campaign to increase the tax compliance of large and/or international businesses. In a January 31 announcement, the IRS’ Large Business and International division (LB&I) said it will . . .  

Americas

Trump says US House border-adjustment plan is overly complex: Richard Rubin & Peter Nicholas / WSJ→

January 17, 2017

See: WSJ. See also, The Hill.

Americas

US should adopt worldwide tax system without deferral, foreign tax credit, professors argue: J. Clifton Fleming, Robert J. Peroni, Stephen E. Shay / SSRN→

November 26, 2016

See: SSRN.

Americas

Guyana and Dominican Republic sign Model 1 FATCA IGAa with US

October 26, 2016

The US Treasury Department has updated its FATCA website, reporting that Guyana and the Dominican Republic have signed Model 1 intergovernmental . . .

Americas

US-Curaçao Model 1 FATCA agreement enters into force

August 5, 2016

US Treasury on August 5 announced on its website that a Model 1 FATCA intergovernmental agreement (IGA) signed by the US and Curaçao entered. . .

Americas

Russia weighs sanctions against UK for permitting tax evasion through Cayman Islands and BVI: Kenneth Rijock / Caribbean News Now→

March 30, 2016

See: Caribbean News Now.

Americas

US MNEs may not file country-by-country reports with IRS for tax years prior to regs’ effective date, official says: Brant Goldwyn / CCH→

March 11, 2016

See: CCH.

Americas

British Virgin Islands tax authority publishes draft code on economic substance

May 7, 2019

The British Virgin Islands International Tax Authority on April 23 published a draft . . .

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Americas

Amazon to again pay $0 US federal tax despite 2018 profits of $11.2b, citing unspecified tax credits, executive stock option break: Matthew Gardner / ITEP→

February 16, 2019
Americas

Google shifted USD 23 billion income to tax haven Bermuda in 2017 using Dutch shell company: Reuters→

January 4, 2019
Americas

Cayman Islands financial institutions to face new CRS reporting thresholds, self-cert requirements

June 12, 2018

Denise Hintzke and Douglas Scott of Deloitte Tax LLP discuss recent, significant changes made to the Cayman Islands common reporting standard (CRS) regime for financial institutions, including an expansion of the pool of persons subject to Cayman CRS reporting and a new process for entity self-certification . . .

Africa

Turkey’s IP tax regime is harmful; new Singapore, Luxembourg, Lithuania, Slovakia laws meet standards, OECD report concludes

May 20, 2018

Turkey’s technology development zone tax regime is harmful to the tax base of other countries while new Singapore, Luxembourg, Lithuania, and Slovakia tax laws favoring intellectual property (IP) are not, a May 17 report prepared by the OECD Forum on Harmful . . .

Americas

Swiss advance information exchange for tax purposes with Singapore, Hong Kong, other financial centres

May 11, 2018

Davide Anghileri of the University of Lausanne discusses the Swiss government’s progress advancing exchange of financial account information for tax purposes with Singapore, Hong Kong, and several countries, including Bahamas and Bahrain, that apply automatic exchange in a non-reciprocal manner . . .

Americas

US government seeks public feedback to aid in prioritizing its tax guidance work

April 28, 2018

The US government has requested advice from the public by June 15 on which areas of the tax law are most in need of clarifying guidance. In Notice 2018-43, the IRS and Department . . .

Americas

US reaches deal with Cayman Islands to exchange country-by-country tax reports on multinationals

March 14, 2018

The US government has announced that it signed a competent authority agreement with the Cayman Islands to exchange country-by-country tax reports . . .

Americas

Apple to pay $38bn tax to repatriate existing offshore earnings: Stephen Nellis / Reuters→

January 17, 2018
Americas

Japan, Colombia agree to sign tax treaty

December 21, 2017

The governments of Japan and Colombia have agreed in principle on the terms of a tax treaty, Japan’s Ministry . . .

Americas

US House Ways and Means removes excise tax on deductible payments to related foreign companies from tax bill: Richard Rubin / Wall Street Journal→

November 7, 2017
Americas

US IRS clarifies research credit safe harbor for taxpayers reporting R&D expense on financial statements: PWC→

September 23, 2017
Africa

US negotiating exchange of country-by-country tax reports with 20 more nations

August 30, 2017

The US IRS is negotiating with 20 countries to annually exchange country-by-country reporting data on large multinational firms . . .

Americas

IRS cancellation of advance pricing agreement was abuse of discretion, US Tax Court rules

August 1, 2017

The US Tax Court has ruled that the IRS abused its discretion when it cancelled two advance pricing agreements (APAs) that it had entered into with a multinational group taxpayer. In the case, Eaton Corp. . . .

Americas

US government temporarily halts issuance of new tax guidance: KPMG→

January 26, 2017

See: KPMG.

Americas

IRS issues tax guidance on US source dividend equivalent payments

January 24, 2017

The US Internal Revenue Service has today published final and temporary (TD 9815) and proposed (REG-135122-16) tax regulations providing guidance to nonresident alien individuals and foreign corporations that hold financial products providing for payments. . .

Americas

Gilead Sciences accused of using deferral, other legal loopholes, to reduce US tax : Americans for Tax Fairness→

August 12, 2016

See: Americans for Tax Fairness. More : Stat.

Americas

FATCA agreement between US and Hong Kong enters into force

August 5, 2016

US Treasury has today announced on its website that a Model 2 FATCA intergovernmental agreement (IGA) signed by the US and Hong Kong entered . . .

Americas

US, Luxembourg agree to tax treaty changes to prevent double nontaxation

June 23, 2016

The US Treasury Department today announced that the US and Luxembourg, during negotiations for new protocol to their 2000 tax treaty, have agreed to provisions to address tax avoidance through triangular and exempt permanent . . .

United States

Joint US congressional committee examines patent box tax break: Joint Economic Commitee →

March 11, 2016

See: Joint Economic Committee.

Americas

US has no plans for retaliatory EU tax for state aid decisions, Stack says: Connor Humphries / Reuters→

March 11, 2016

See: Reuters.

Americas

Bermuda likely to be removed from EU list of non-cooperative jurisdictions, finance minister says: Government of Bermuda→

April 9, 2019
Americas

Barbara Angus appointed EY Global Tax Policy Leader

February 15, 2019

EY today announced that Barbara Angus has been appointed . . .

Digital Economy

US pushing for global adoption of minimum tax, revised profit allocation rules

December 17, 2018

The US is seeking worldwide agreement on proposals that would significantly alter the international tax system, aiming to preempt a threatened EU digital services tax and bring stability to the international tax system, Treasury officials said at  . . .

Americas

Cayman Islands minister to meet with EU officials about tax blacklist, planning public consultations on new laws requiring substance for tax residence: James Whittaker / Cayman Compass→

September 19, 2018
No Picture
Africa

Swiss Federal Council adopts MLI

August 22, 2018

The Swiss Federal Council on August 22 adopted a dispatch on the Multilateral Convention to Implement Tax Treaty . . .

Americas

US Supreme Court agrees to consider constitutionality of South Dakota law imposing sales tax on online, remote merchants: Greg Stohr / Bloomberg→

January 12, 2018

     

Americas

Argentina tax reform adds sixth method, other transfer pricing revisions: KPMG→

January 8, 2018
Americas

US Senate proposal for minimum tax on foreign intangible income may violate WTO rules: Rebecca Kysar / Medium→

November 13, 2017
Americas

US Tax Court rules transactions between related companies create “United States property”

August 1, 2017

The US Tax Court has ruled that transactions between a US parent and its controlled foreign corporations (CFCs) gave rise to “United States property” under section . . .

Americas

US Tax Court decision in Grecian Magnesite could upend international tax regime for partnerships

July 18, 2017

Monte Jackel follows up on his earlier article on the US Tax Court’s decision in Grecian Magnesite  discussing the collateral effects the ruling could have on the international tax rules for partnerships . . . 

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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
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  • 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
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  • The Evolution of Transfer Pricing in Saudi Arabia
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  • 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

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • Singapore adopts BEPS-compliant IP tax incentives by Edmund Leow | posted on March 24, 2021
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019

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