Americas
Americas
Americas
Americas
Americas
Duff & Phelps forms alliance with BaseFirma
BaseFirma, an international transfer pricing advisory firm with a major presence in Latin America, has joined Duff & Phelps’ Transfer Pricing Alliance, Duff & Phelps announced . . .
Americas
IRS tax regulations and the 1 for 2 Trump executive order
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses President Trump’s executive order mandating that for every new regulation issued, two must be removed, noting that it will be very difficult to apply this order to US tax regulations . . .
Americas
Americas
Americas
US IRS issues final and proposed tax regulations on US property held by CFCs involving partnerships
The US IRS today published final regulations (TD 9792) providing rules regarding US property held by a controlled foreign corporation (CFC) in connection with certain transactions . . .
Brazil
UN tax committee to consider major updates to transfer pricing manual, model tax treaty
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
Africa
Americas
Americas
US IRS eases FATCA compliance
The US IRS on January 19 announced in Notice 2016-08 that it will amend existing regulations under sections 1441–1464 and 1471–1474 regarding the timing of submitting preexisting . . .
Americas
Americas
CIAT-SECO partnership strengthens Latin American and Caribbean tax administrations
Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium, discuss recent activities of the Inter-American Center of Tax Administrations (CIAT) and the State Secretariat for Economic Affairs of the Swiss Government (SECO) to assist tax administrations in Bolivia, El Salvador, Guatemala, Guyana, Honduras, and Nicaragua with transfer pricing and other issues . . .
Americas
Americas
Americas
Americas
Americas
Americas
Americas
Americas
Americas
Americas
Americas
OECD publishes peer review reports on tax dispute resolution in US, Belgium, Canada, Netherlands, Switzerland, UK
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
Americas
Americas
Cayman Islands, Belize to adopt BEPS international tax standards
The Cayman Islands and Belize have become members of the “Inclusive Framework on BEPS,” the OECD announced today. The inclusive framework is a group of countries that have pledged to put into place minimum standards aimed at preventing tax avoidance and improving . . .
Americas
Americas
Americas
Americas
US finalizes regs on outbound transfers of foreign goodwill
The US IRS has released final regulations (TD 9803) under section 367 which eliminate the favorable tax treatment of outbound transfers . . .
Americas
The final debt-equity regulations: planning to comply
Robert M. Gordon and Jennifer Crawford of True Partners Consulting LLC discuss the final US debt-equity regulations, focusing on the regs’ new documentation requirements for related party debt . . .
Americas
Americas
Medtronic wins transfer pricing dispute in Tax Court
Medical device manufacturer Medtronic on June 9 won its transfer pricing dispute with the IRS in Tax Court, beating back the IRS’s claim that the medical device manufacturer should have reported increased US royalty payments and 2005 and 2006 from a related Puerto Rico . . .
Americas
US agrees to FATCA exception for Swiss accounts held by lawyers, notaries for clients
The US and Switzerland have agreed that Swiss bank account owner identities can remain confidential for purposes of the Foreign Account Tax Compliance Act (FATCA) in some instances where the account is held . . .
Americas
Americas
Americas
Americas
