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EU finance ministers blast US international tax reform proposals
Finance ministers from Italy, Germany, France, the UK, and Spain have written to US Treasury Secretary Steven Mnuchin warning that provisions in the US tax reform bill contravene the US’s tax treaty and World Trade Organizations (WTO) obligations as well as international agreements reached under the OECD/G20 base erosion profit shifting (BEPS) plan. The ministers – Italy’s Pier Carlo Padoan, Germany’s . . .
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FATCA/CRS
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Canada Federal budget 2017 proposes base erosion rule for foreign branches of life insurers
Canada’s Federal budget 2017, released today, proposes to amend the Income Tax Act to prevent income from the insurance of Canadian risks from being shifted to a foreign branch of a Canadian life insurer . . .
Americas
Americas
Paul Caron named Dean of Pepperdine Law School
Paul L. Caron has been named dean of Pepperdine School of Law, Pepperdine University has . . .
Americas
US FATCA IGAs with UAE, Portugal, Croatia, Montserrat enter into force; IGAs signed with Anguilla, Greenland
US Treasury has announced on its website that FATCA intergovernmental agreements (IGAs) have entered into force with the UAE, Portugal, Croatia, Montserrat and that IGAs . . .
Americas
Americas
UK-Uruguay tax treaty enters into effect
The new UK-Uruguay tax treaty has entered into effect, the UK’s Foreign & Commonwealth Office announced . . .
Africa
Switzerland consults on introducing automatic exchange of tax information with 22 countries
The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .
Americas
Panama joins BEPS inclusive framework
The OECD has today announced that Panama has become the 87th member of the “inclusive framework on BEPS,” which is a group of countries . . .
Americas
US and Ireland commence tax treaty renegotiation: what could change
Steptoe & Johnson LLP partner, Amanda Varma, discusses the recent announcement that the US and Ireland are renegotiating their tax treaty, and identifies provisions in the existing US-Ireland tax treaty that the US will likely try to modify . . .
Americas
US and Singapore aim to sign TIEA and reciprocal FATCA IGA by year end
In a joint statement issued after their August 2 meeting, US President Barack Obama and Singapore Prime Minister Lee Hsien Loong pledged to negotiate and sign by the end of 2016 a tax information exchange agreement (TIEA) and a FATCA intergovernmental agreement (IGA ) that provides . . .
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US, Costa Rica sign agreement to exchange tax information
The US and Costa Rica on May 23 signed a tax information exchange agreement. The agreement is not yet in force.
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US Tax Court decision has big implications for non-US partners in US partnerships
Monte A. Jackel, Senior Counsel at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court’s July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .
Americas
Mexico: transfer pricing documentation and country-by-country reporting rules finalized
Yoshio Uehara, César De la Parra, and Ignacio Mosquera of Chevez, Ruiz, Zamarripa, analyze final rules, issued by the Mexican tax authorities April 3, that implement the transfer pricing documentation and country-by-country reporting scheme set out in Action 13 of the OECD/G20 base erosion and profit shifting (BEPS) plan agreements . . .
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Ireland granted Apple illegal state aid through tax rulings sanctioning stateless income, EU says
The European Commission on August 30 announced it has concluded that Ireland granted Apple about €13 billion (USD 14.5 billion) in illegal state aid by issuing tax rulings to the company that inappropriately lowered its tax liability in 2003–2014. To restore fair competition, Apple must repay the aid to plus interest, the Commission said. The determination comes after a two year investigation . . .
More:
Apple CEO calls state aid decision “political crap”: Los Angeles Times→
Obama to address Apple decision at G20: AP→
Irish Cabinet agrees to appeal Apple decision: RTE News→
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