Americas
Americas
Americas
US professors advocate international tax reform before Senate Finance panel
Sam Olchyk and Kiley Boland, Venable LLP, Washington discuss the a US Senate Finance Committee hearing held October 3, where tax professors expressed discontent with the current US international tax system and agreed that American companies are treated unfairly in comparison to foreign companies operating in the US . . .
Africa
Transfer pricing comparables “toolkit” reflects realities of developing nations, UN official says
A new “toolkit” which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm’s length approach can work for all nations but is also an imperfect, “not scientifically pure,” document, a UN official said July 18. Michael Lennard . . .
Americas
Americas
Americas
Why the House GOP’s destination-based cash flow tax doesn’t work for partnerships
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about difficulties applying the House GOP’s destination-based cash flow proposal to partners and partnerships . . . .
Americas
Americas
Americas
Natan Leyva joins Vinson & Elkin
International tax lawyer Natan Leyva has joined Vinson & Elkin’s Washington, DC office, the firm announced today . . .
Americas
US and Dominican Republic sign Model 1 FATCA IGA
The US Treasury Department today updated its FATCA website, reporting that the Dominican Republic the US signed a Model 1 intergovernmental . . .
Americas
Americas
Americas
Switzerland and Canada agree on automatic exchange of financial account information
Switzerland and Canada on February 4 signed a joint declaration to work toward implementing automatic exchange of information on the financial accounts . . .
Americas
Americas
Americas
Africa
OECD officials discuss international tax and transfer pricing agenda
Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .
Americas
Americas
Americas
Americas
Americas
US IRS reassessing transfer pricing strategy following court losses, unable to sign all country-by-country reporting CAAs
US IRS and Treasury officials joined tax practitioners and corporate tax executives today to discuss key international tax and transfer pricing developments at the 30th Annual Institute on Current Issues in International Taxation, cosponsored by George Washington University Law School and the Internal Revenue . . .
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Europe
Americas
Americas
Americas
Americas
US IRS allows early parent-surrogate filing for country-by-country reporting
The US IRS on January 19 issued guidance providing a procedure for the ultimate parent entity of a US MNE group to voluntarily file Form 8975 for early reporting periods. The filing is required effectuate . . .
Americas
US-Cambodia FATCA IGA enters into force
The US Treasury today announced on its website a Model 1 FATCA intergovernmental agreement (IGA) signed the US-Cambodia entered into . . .
Americas
Americas
Featured News
Sanders joins Dems urging public country-by-country tax reporting for US multinationals
US Democratic presidential candidate Sen. Bernie Sanders (I-VT) and three Senate colleagues on June 8 urged the Obama administration to require public disclosure of country-by-country tax reports of large multinational . . .
Americas
Canadian subsidiary may deduct interest on intercompany loan, court rules
Carrie Smit, a partner with Goodmans LLP, Toronto, analyzes the Canadian Federal Court of Appeals March 4 decision in The TDL Group Co. v. The Queen, which concluded that a Canadian company is entitled to deduct interest on an intercompany loan used to acquire shares of its US subsidiary. . .
Americas
Americas
Americas
Americas
US planning international tax guidance on BEAT, GILTI, transition tax, Treasury official says
The US intends to issue proposed tax regulations next month addressing the section 965 transition tax followed by year-end guidance on the GILTI, BEAT, and other international tax provisions introduced in the 2017 Tax Cuts and Jobs Act, said Lafayette (Chip) G. Harter, Deputy Assistant Secretary (International Tax Affairs) at US Treasury during the 2018 OECD International Tax Conference, held . . .
Africa
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