Americas
US, Belgium FATCA agreement enters into force
US Treasury has announced on its website that a Model 1 FATCA intergovernmental agreement (IGA), a supplemental . . .
US Treasury Inspector General suggests ways to improve IRS transfer pricing exams
The US Treasury Inspector General (TIGA) on November 3 released a report outlining its recommendations on how to improve the IRS’s handling of transfer pricing issues. The report includes the . . .
Brazil signs global tax agreement for automatic exchange of financial information
Brazil has signed a multilateral competent authority agreement that creates the framework for the automatic exchange of financial account information under the OECD/G-20 common reporting . . .
Trump’s tax plan calls for deemed repatriation of overseas profits
US presidential candidate Donald Trump’s revamped tax plan, unveiled today, reiterates his earlier call for a deemed repatriation of all corporate profits held offshore at . . .
India extends FATCA due diligence deadline for accounts that become high-value
The Indian government has today announced that it has extended FATCA due diligence deadlines . . .
US IRS finalizes anti-loss importation tax regulations
The US IRS today published in the Federal Register final anti-loss importation regulations, making mostly minor changes from tax proposed regulations . . .
OECD proposes new pension residence rules for model tax treaty
David W. Powell and Kevin Walsh of the Groom Law Group analyze recently issued draft revisions to the OECD Model Tax Convention concerning the tax residence of pension funds, and compare the OECD provisions to those in the updated US model tax treaty. . . .
US tax officials discuss 2016 BEPS agenda, country-by-country reporting, EU state aid controversy
There appears to be no slow down in OECD activity even though work on the base erosion profit shifting (BEPS) deliverables is complete, Robert Stack, Treasury Deputy Assistant Secretary . . .
OECD set to release 2017 transfer pricing guidelines, clarify MLI effect on tax treaties, officials say
The OECD expects to soon release an important update to its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, tax officials said during a June 26 webinar. Officials also discussed the OECD’s coming release of a discussion draft . . .
Cayman Islands issues guidance for financial institutions on common reporting standard obligations
The Cayman Islands Department for International Tax Cooperation on April 13 issued guidance for financial institutions on the common reporting . . .
Support builds among US House GOP members for Auerbach’s destination-based tax: Steve Lohr / The New York Times→
See: The New York Times. For Professors Reuven S. Avi-Yonah and Kimberly A. Clausing’s critique of the plan, see: SSRN.
Brazil, Guernsey, Jersey, Isle of Man, Latvia sign agreement for exchange of tax reports on multinationals
Brazil, Guernsey, Jersey, the Isle of Man, and Latvia have signed a multilateral agreement which sets out the parameters for the automatic exchange between tax administrations of country-by-country tax reports on . . .
Canada, Israel sign tax treaty, text available
US FATCA agreement with Curaçao enters into force
A FATCA intergovernmental agreement (IGA) between the US and Curaçao has entered into force, the US government . . .
US, Trinidad and Tobago sign Foreign Account Tax Compliance Act (FATCA) agreement
The US Treasury Department updated its FATCA website on August 22, reporting that Trinidad and Tobago and the US have signed a Model 1 intergovernmental agreement (IGA). Trinidad and Tobago has been treated as if it has had . . .
Zvi Hahn joins Steptoe’s tax group
Zvi Hahn has joined Steptoe & Johnson’s New York tax group as a partner, the firm announced . . .
Seychelles issues guidance to financial institutions on FATCA reporting
The Seychelles government has released guidance notes for financial institutions on how to . . .