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US Senate passes tax reform bill increasing tax rate on deemed repatriation of foreign profits
The US Senate early Saturday morning passed its version of tax reform on a 51-49 vote. Like the House bill, passed in November, the Senate bill’s international tax provisions would dramatically alter the taxation of US and foreign-parented multinationals. In a late change, the Senate increased the tax rate on deemed repatriations of currently deferred . . . .
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US, Canada sign competent authority agreement for exchange country-by-country tax reports
Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . .
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Eli Miller appointed US Treasury Chief of Staff
Eli Miller will serve as US Treasury Chief of Staff, newly appointed US Secretary of the Treasury, Steven T. Mnuchin, announced . . .
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New US subpart F tax regulations address foreign partnerships, active rents and royalties exception
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss final regulations released November 2 that clarify various issues arising under subpart F related concerning foreign partnerships and active rents and royalties . . .
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Indian tax official sees expanded role for BEPS inclusive framework, addresses transfer pricing local file
The countries that have joined the inclusive framework established to carry out the work of the OECD/G20 base erosion profit shifting (BEPS) project are likely to eventually take on international tax work outside of the BEPS . . .
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Japan and Panama to negotiate tax information exchange agreement
The Japanese government has today announced that it will begin negotiations with Panama for a new. . .
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US tax rules would curb inversions through earnings stripping limits, stopping serial inversions
The US Treasury today announced a package of tax rules designed to discourage corporate inversions, including measures that restrict earnings stripping . . .
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Companies face setback in challenge to District of Columbia’s use of Chainbridge transfer pricing method
Mark Nachbar and Mary Bernard of Ryan, LLC note the release of a surprising January 26 ruling in actions, brought by Hess, Exxon, and Shell, challenging the District of Columbia’s use of transfer pricing software developed by Chainbridge Software to assess millions in tax liabilities against them . . .
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US IRS issues final reporting, record keeping rules for foreign-owned disregarded domestic entities
The US IRS on December 13 published final tax regulations (T.D. 9796) under sections 6038A and 7701 that require wholly foreign-owned domestic disregarded entities to be treated as a domestic corporations, separate from their owners . . .
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Florida and Delaware LLPs and LLLPs to be taxed as corporations, Canadian tax officials say
Kabir Jamal, an attorney with Goodmans LLP, Toronto, discusses statements made by Canadian Revenue Agency officials at a conference last week announcing the agency’s decision to classify Florida and Delaware LLPs and LLLPs as corporations for income tax purposes . . .
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US disputes need for special digital economy tax rules, seeks consensus on profit allocation issues
The highly-anticipated interim report of the Task Force on the Digital Economy (TFDE), slated for release in April, will state that countries are divided on a long-term solution for taxing the digital economy, with the US arguing that there is no need for special tax rules in this area, said Chip Harter, Deputy Assistant Secretary (International Tax Affairs) at the US Department of the Treasury. Speaking in Washington at a Tax Council Policy Institute conference held . . .
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US Republican tax reform plan would rewrite international tax system
US House Republicans today presented their long-awaited tax reform bill, proposing to dramatically change the US international tax system.As expected, the Republican proposal includes a move to a territorial tax system accomplished by a foreign dividends received deduction. This is coupled with a deemed repatriation of existing earnings held offshore. The bill sets the deemed . . .
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