Americas
EU updates list of non-cooperative jurisdictions in taxation matters
Today the Council of the European Union removed Barbados, Grenada, the Republic of Korea, Macao SAR, Mongolia, Panama, Tunisia and the United Arab Emirates from the EU list of non-cooperative jurisdictions in taxation matters, writes Davide Anghileri of the University of Lausanne, Switzerland . . . .
Canada, Switzerland exchange notes on automatic exchange of information
Canada and Switzerland on December 23 exchanged notes for automatic exchange of information in tax . . .
Apple may lose EU State aid dispute, tax experts say
The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company’s subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .
US IRS adds two new international tax projects to priority guidance list
The US IRS on August 15 released its list of priority tax guidance projects for 2016-17, revealing that the agency has decided to work on issuing guidance in the areas of foreign currency contracts and country-by-country . . .
17 nations placed on EU blacklist of tax havens
Davide Anghileri of the University of Lausanne discusses the EU’s tax blacklist, released December 5, which identifies 17 “non-cooperative jurisdictions” and warns many others that they could be listed in the future if they do follow through with commitments to improve specified aspects of their tax regimes . . .
US court determines IRS properly denied discretionary tax treaty benefits
Amanda Varma and Brigid Kelly of Steptoe & Johnson, Washington, discuss the implications of the US district court’s decision Starr International Co. Inc. v. US, issued August 14, where the court concluded that the US competent authority acted reasonably when it denied a taxpayer’s request for discretionary tax treaty benefits under the US-Switzerland tax treaty. . .
Tax officials crafting plan to jointly identify large multinationals with low risk of tax avoidance
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Tax rules for US partners of foreign partnerships that hold CFC stock need clarity
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
Japan, Bahamas agree to automatic exchange of financial information for tax purposes
Japan and the Bahamas on February 9 signed a protocol to their tax information exchange agreement (TIEA), agreeing to upgrade the agreement by providing for automatic exchange . . .
Sen. Bill Cassidy joins US Senate Committee on Finance
Senator Bill Cassidy (R-La.) will serve on the US Senate Finance Committee in the 115th Congress, replacing retiring Sen. Dan Coats of Indiana. His assignment was announced Tuesday by Finance . . .
Facebook battling IRS in Tax Court over royalty income from related Irish company
Facebook has filed a petition in US Tax Court, contesting IRS adjustments that increased the social media giant’s royalty income by about $85 million in 2010 on account . . .