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US IRS issues final tax regulations on disregarded stock in inversions
The US IRS has published final and temporary (TD 9812) and proposed (REG-135734-14) tax regulations under section 7874 designed to fight tax avoidance associated with the inversion . . .
Americas
US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
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New Zealand proposes rules to combat multinational tax avoidance through use of hybrid mismatches
The New Zealand government has today released for discussion proposed measures to prevent multinational corporations from avoiding tax through use of hybrid mismatch . . .
Americas
Americas
US business groups file lawsuit challenging tax inversion regulations
Two US business groups today filed a lawsuit in Federal court challenging the validity of US tax regulations aimed at stopping “serial” corporate . . .
Africa
36 non-OECD, non-G20 countries join BEPS international tax effort
Thirty-six countries and jurisdictions that are neither OECD nor G20 members have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, and 21 more are expected to join in the coming months, the . . .
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US President signs tax reform into law, SEC follows up with reporting guidance
US President Donald Trump today signed the Tax Cuts and Jobs Act into law, which, among other things, slashes the corporate tax rate, and completely changes the US’s international tax system. Securities Exchange Commission staff also followed up today with new guidance on how reflect the impact of the new law in . . .
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Trump’s tax regulation order: what (besides earnings stripping) could be on the chopping block?
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses a Trump administration executive order, issued last Friday, mandating the review of tax regulations, noting that those hoping the order will lead to the repeal of US earnings stripping and/or inversion tax regulations may wind up disappointed . . . .
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Tax information exchange agreement between Isle of Man, Turks and Caicos enters into force
The Isle of Man government on December 14 announced that an agreement for the exchange of information relating to tax matters with the government . . .
Africa
BRICS country tax officials express support for “inclusive framework” on BEPS
Heads of revenue of the BRICS countries – Brazil, Russia, India, China, and South Africa – at a meeting held December 5–6 in Mumbai, expressed support for measures . . .
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Americas
Proposed debt/equity tax regs need revision, Democrat and Republican lawmakers say
In separate letters, US House Ways and Means Committee Republicans and Democrats have expressed concerns about proposed tax regulations issued last April that recharacterize some cross-border loans . . .
Africa
Karanja to head OECD/UN Tax Inspectors Without Borders initiative
Kenyan tax official, James Karanja will lead the joint OECD/UN Tax Inspectors Without Borders (TIWB) initiative effective April 11, the OECD announced today. Karanja is assistant manager of the international tax . . .
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