Americas
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US Democrats offer bill to curb tax inversions by limiting earnings stripping
Two ranking US Democrats today introduced a tax bill designed to lessen the attractiveness of corporate inversions by limiting companies’ ability . . .
Americas
US confirms plan to begin bilateral APA negotiations with India
The US IRS today confirmed that, beginning February 16, the US competent authority will accept applications for Indian advance pricing agreements (APAs), citing. . .
Americas
Japan and Chile sign first tax treaty
Japan and Chile signed a tax treaty on January 22, the first such agreement between the nations, Japan’s . . .
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Africa
EU removes Bahamas, Saint Kitts and Nevis from tax blacklist, agrees on rules for intermediaries
MNE Tax contributing editor, Davide Anghileri, discusses a Council of the European Union May 25 meeting where EU States agreed on new rules for regulating intermediaries that design or promote tax planning schemes; new wording to be included in agreements with third countries on good governance in tax matters; and moving the Bahamas and Saint Kitts and Nevis from the EU’s tax blacklist list to its “gray list” . . . ,
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Mexico: transfer pricing adjustment rules adopted
Yoshio Uehara and Ignacio Mosquera of Chevez, Ruiz, Zamarripa y Cía., Mexico City, discuss new Mexican provisions allowing for transfer pricing adjustments as of January 1 . . .
Americas
Szubin to serve as US Treasury acting secretary
Adam Szubin will serve as Acting Secretary of the US Treasury effective immediately, Treasury announced in a . . .
Americas
US, St. Lucia FATCA IGA enters into force
The US Treasury Department has today updated its FATCA website, reporting that a Model 1 FATCA intergovernmental . . .
Americas
Americas
OECD releases 17 comments on draft addressing MNE tax avoidance though branch mismatches
The OECD has released 17 comment letters responding to a draft report that explores how countries can improve their tax laws to counteract tax avoidance by multinational enterprises (MNEs) through . . .
Americas
Americas
Treasury’s plan to fix to US debt-equity tax regs falls short, GOP lawmakers say
US Treasury’s plan to revise six problematic areas in the proposed section 385 debt-equity regulations does not go far enough to allay concerns about regs’ negative impact on the US economy, Republican lawmakers . . .
Americas
Canada’s new international business tax proposals: a closer look
Goodmans LLP tax attorney, Kabir Jamal, provides an analysis of the international tax proposals in the Canadian government’s draft tax bill, issued July 29, including measures that address foreign exchange gains on foreign-currency debt, back-to-back loan and royalty arrangements, and country-by-country reporting . . . .
Europe
EU State aid probe into tax rulings extends to group financing companies, TNMM use
The EU Commission on June 3 released a working paper identifying several categories of Member State transfer pricing rulings that raise potential State aid concerns because they sanction profit allocations. . .
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Brazil clarifies transfer pricing rules, approves protocol to tax treaty with Denmark
Francisco Lisboa Moreira, a partner with Bocater, Carmargo, Costa e Silva, Rodrigues, São Paulo, provides an update of recent Brazilian tax developments of interest to MNEs, discussing new Brazilian transfer pricing guidance and the Brazilian Congress’s approval of protocol to the Brazil-Denmark tax treaty . . .
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Africa
