The U.S. IRS and Caterpillar, Inc., on July 31, filed a stipulated settlement, ending their U.S. Tax Court dispute over whether royalty income should be allocated to Caterpillar from the company’s Belgium and French subsidiaries. Tax Court Docket No. 010790-13, For analysis of the dispute, see post by
Pfizer Inc.’s attempted takeover of British pharmaceutical rival, AstraZeneca, if successful, could yield a massive loss to the U.S. Treasury as its offshore profits could permanently escape taxation. See, Jessie Drucker and Zachary R. Mider, Bloomberg; Richard Murphy, Tax Research U.K.; Liz Hoffman, Wall Street Journal; Jia Lynn Wang. Washington Post; Matthew Herper, Forbes
VAT refunds owed Procter & Gamble, Unilever, and Colgate totaling hundreds of millions of dollars were withheld by the Mexican government while the companies were under investigation for tax avoidance, writes Henry Romero of Reuters in a September 1 article. See: Reuters.
Ireland’s Minister of Finance Micheal Noonan on March 11 signed an order to commence legislation that establishes the Irish collective asset-management vehicle (“ICAV”), a new Irish corporate vehicle for investment funds. The ICAV will be a corporate entity with . . .
The US has released the text of an agreement signed by competent authorities of the US and Kazakhstan which concerns the eligibility of entities that are treated as fiscally transparent under a double tax agreement signed by the countries
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An Australian Taxation Office (ATO) official, on May 22, confirmed that Australia and five other nations are collaborating to investigate the global tax planning of multinationals operating in the e-commerce industry.
Mark Konza, ATO Deputy Commissioner, International, said that Australia was “currently involved in a cooperative compliance approach” with five other nations. The collaboration led to the production of an
Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
The British Virgin Islands International Tax Authority on March 20 released guidance notes designed to provide practical assistance entities and their directors, officers, and advisers in complying with obligations under FATCA. See, FATCA Guidance, Version 2.0
US Senator Marco Rubio (R., Fla.), a likely 2016 Republican presidential candidate, and Senator Mike Lee (R., Utah) on March 4 released a tax plan that includes a proposal to adopt a territorial tax system. The Rubio-Lee plan would also . . .
Diana L. Wollman, former IRS director of international strategy in the Large Business and International Division, will join Cleary Gottlieb’s tax practice in New York as a partner where she will focus on tax controversy . . .
The Canadian government on January 7 announced that launch of the Canada Revenue Agency’s (CRA) Electronic Funds Transfer (EFT) initiative, which effective January 1, requires financial intermediaries, including banks, to report to the CRA incoming and outgoing international EFTs of $10,000 or more. The. . .
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
The US IRS on October 27 released new questions and answers on the FATCA International Data Exchange Services (IDES) system on its website and listed approved certificate authorities.
The new Q&As are as . . .
The European Court of Justice, in Kronos International Inc. released Sept 11, has ruled that a US registered company resident in Germany may assert that German tax rules violate free movement of capital, but the company may not claim freedom of establishment rights. The ECJ went on to reject the company’s contention that Germany’s tax rules in effect at the time, which permitted a set off for . . .
Hein & Associates LLP, on August 12, announced that Stephen T. Williams will be joining the firm’s Denver office as National Director of International Tax Services. Williams is formerly with PwC, Calgary. Release