Americas

Authors examine use of foreign tax holidays by US MNEs: Travis Chow, Jeffrey L. Hoopes, Edward L. Maydew / SSRN→

August 31, 2017

Americas

Authors consider US repatriation tax’s effect on bank loan rates: Zhiming Ma, Derrald Stice, Danye Wang / SSRN→

April 12, 2017

Americas

Cayman Islands lists reportable jurisdictions for CRS: KPMG→

April 5, 2017

Americas

Foreign captive insurance companies not exempt, IRS rules: KPMG→

March 29, 2017

See: KPMG.

Americas

US FATCA IGAs with Panama, Georgia enter into force; IGA with Antigua and Barbuda signed

November 7, 2016

The US Treasury Department today updated its FATCA website, reporting that Model 1 intergovernmental agreements (IGAs) entered . . .

Americas

Mark Trivette joins Alvarez & Marsal Taxand’s Atlanta office

October 18, 2016

Mark Trivette has joined Alvarez & Marsal Taxand, Atlanta, as its new Managing Director . . .

Americas

US Democrats introduce bill to close foreign reinsurance tax loophole

September 29, 2016

US Democrats on Wednesday introduced a bill designed to prevent foreign insurance groups from avoiding US tax by paying reinsurance premiums to affiliates located in tax . . .

Americas

European Parliament debate reveals strong support for Commission’s state aid verdict in Apple case: European Parliament→

September 14, 2016

See: European Parliament.

Americas

US criticizes EU probe of multinational corp tax as Apple decision nears

August 24, 2016

The Obama Administration, in a letter and white paper released today, ramped up its criticism of European Commission efforts to force large multinational firms to pay back amounts deemed illegal state aid that were allegedly received through overly generous tax rulings, known . . .

Americas

Tax officials preview coming OECD guidance on profit splits, attribution of profits to PEs

June 12, 2016

Tax officials provided an update of international tax and transfer pricing guidance currently being developed at the OECD, including work on profit splits and on attribution of profits to permanent establishments (PEs), at Washington DC conference sponsored by the OECD, USCIB, and . . .

Americas

Proposed US section 385 regs would have “profound impact,” recharacterizing routine related party debt transactions as equity as of April 4: PwC→

April 8, 2016

See: PwC. More: Skadden, Arps, Slate, Meagher & Flom.

More News

US IRS issues regulations on partnership allocations of creditable foreign tax expenditures

February 4, 2016

The IRS on Wednesday released final, temporary, and proposed regulations applicable to partnerships that claim the foreign tax credit for foreign income taxes. The regulations. effective February 4, clarify aspects of the section 1.704-1(b)(4)(viii) safe harbor rule that allows allocations of. . .

Americas

Belize signs and Monaco ratifies BEPS mulitlateral tax treaty

January 13, 2019

The OECD on January 11 announced that . . .

Americas

Bermuda updates country-by-country reporting guidance for large MNEs

August 10, 2018

Bermuda’s government has released an updated version of its guidance notes for large multinationals on country-by-country reporting. The guidance . . .

Americas

US IRS clarifies instructions for country-by-country reporting forms

July 25, 2018

The US IRS today issued clarifications to the instructions for filing Schedule A (Form 8975) dealing with country-by-country reporting for multinationals. The new instructions detail . . .

Americas

Boston Scientific, IRS finalize transfer pricing settlement: Brad Perriello / MassDevice→

May 31, 2018

Americas

New US tax law will increase tax on companies that inverted: Jonathan D. Rockoff and Nina Trentmann / Wall Street Journal→

February 13, 2018

Americas

Ireland, Bahamas tax information exchange agreement enters into effect

February 7, 2018

A tax information exchange agreement between Ireland and the Bahamas has entered into effect, Irish Revenue announced February 7. The agreement, signed January 12, 2015, allows for the exchange of information . . .

Americas

US tax reform, particularly lower corporate rate, will boost US and global growth through 2020, IMF predicts: Josh Zumbrun / Wall Street Journal→

January 23, 2018

Americas

Japan, Argentina negotiating tax treaty

January 9, 2018

Japan’s Ministry of Finance today announced that the governments of Japan and Argentina will commence negotiations . . .

Americas

Tax reform and regulatory simplification top US tax agenda

December 3, 2017

David J. Kautter, the Trump Administration’s new interim IRS commissioner and Treasury Assistant Secretary for Tax Policy, said December 1 that his two highest priorities are to enact and implement US tax reform and to simplify existing . . .

Americas

Colombia clarifies country-by-country reporting obligation: EY→

May 11, 2017

Americas

IRS loss in Amazon reveals need to repeal cost sharing, check-the-box regs, prof says: Reuven S. Avi-Yonah / SSRN →

May 3, 2017

Americas

IRS signed fewer APAs in 2016, statistics show

March 27, 2017

The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .

EU prepares challenge to Trump border tax plan: The Telegraph→

February 15, 2017

See: The Telegraph.

Americas

Japan, Bahamas initial change to tax treaty

February 2, 2017

Japan and the Bahamas have agreed in principle to partially modify their 2011 tax treaty, Japan’s Ministry . . .

Americas

Panama updates transfer pricing documentation rules: PWC→

January 20, 2017

See: PWC.

Americas

Peru increases corporate rate, reduces dividend withholding tax: EY→

January 6, 2017

See: EY.

Americas

Bahamas must seek TIEAs now to avoid EU, OECD blacklisting, lawyer says: Neil Hartnell / Tribune 242→

September 28, 2016

See: Tribune 242.

Africa

Jamaica, Angola, Seychelles join BEPS effort to crack down on MNE tax avoidance

July 19, 2016

Jamaica, Angola, and Seychelles have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, the . . .

Americas

US IRS Appeals rules Delphi not liable for US tax on worldwide profits under inversion rules: Dustin Walsh / Crain’s Detroit Business→

April 14, 2016

See: Crain’s Detroit Business. More: SEC Form 8K (Streetinsider.com), Reuters, Wall Street Journal.

Americas

Canadian budget adopts CbC reporting and exchange of tax rulings, restricts back-to-back loans and royalties: Stikeman Elliott→

March 23, 2016

See: Stikeman Elliott. More: Osler, Hoskin, & Harcourt , Aird & Berlis, EY. Original source: Budget.

Americas

Tyco reaches tentative settlement with IRS in earnings stripping dispute: MarketWatch: Bob Tita / Marketwatch→

January 20, 2016

See: MarketWatch. More: Street Insider.

Africa

Assessment of “harmful” tax regimes released, inquiry moves to low-tax jurisdictions

January 31, 2019

The OECD has published a progress report detailing whether countries are meeting their commitments to . . .

Americas

New Brazil MAP guidance aids taxpayers seeking cross-border tax relief

January 3, 2019

Francisco Lisboa Moreira discusses Brazil’s new mutual agreement procedure (MAP) guidance, which aims to meet global standards . . .

Americas

US foreign tax credit regs address TCJA changes

November 28, 2018

The US IRS and Treasury today issued key proposed regulations addressing the foreign tax credit for both businesses and individuals. The 312-page regulations . . .

Americas

Proposed US deemed repatriation regulations provide clarity but reject taxpayer suggestions

August 8, 2018

Friedemann Thomma and Lauren Keller of Venable LLP discuss comprehensive proposed regulations, released August 1, that address the Section 965 deemed repatriation “toll charge” imposed on US persons with foreign earnings accumulated offshore . . .

Americas

US Tax Court releases decision in Illinois Tool Works repatriation case

August 7, 2018

The US Tax Court on August 6 released its decision in Illinois Tool Works, sanctioning a US MNE’s strategy to repatriate foreign earnings held by . . .

Americas

US, Indonesia agree to exchange country-by-country data on multinationals to prevent tax avoidance

July 2, 2018

The US and Indonesia have signed a competent authority agreement providing for the exchange of country-by-country reporting data, US Treasury . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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