Americas
Americas
Americas
Following Validus, US IRS concludes excise tax inapplicable to wholly foreign insurance transactions
The US IRS, in Rev. Rule 2016-3 issued on January 19, has announced that it will no longer apply the one-percent excise tax under section 4371(3) to premiums . . .
Americas
Mexico transfer pricing comparability adjustments, the search for consensus
Jesús Aldrin Rojas a partner at QCG Transfer Pricing Practice, Mexico City, provides a comprehensive overview of a recent conference sponsored by the Universidad Panamericana Campus Mixcoac where Mexican tax officials and transfer pricing practitioners discussed new Mexican transfer pricing guidance . . .
Americas
Americas
Americas
Americas
Africa
Americas
Americas
Americas
Americas
Americas
Americas
Ireland, US multinationals to face new tax landscape in 2018
Jim Stewart, Trinity Business School, Trinity College, Dublin discusses how EU tax authorities’ increasing challenges to the tax strategies of US multinationals, their access to information about MNE activities, US tax reform, and the net effect of ‘correlative adjustments,’ are creating a new tax environment for US MNEs, Ireland, and international taxation in general . . .
Americas
Americas
Americas
Americas
Americas
Hong Kong signs AEOI pacts with Belgium, Canada, Guernsey, Italy, Mexico and Netherlands
Hong Kong signed treaties with six countries on March 16 for the automatic exchange of financial account information (AEOI) in tax. . .
Americas
Japan, Panama tax information exchange agreement to enter into force
A tax information exchange agreement between Japan and Panama, signed August 25, 2016, will enter into force on March 12, Japan’s Ministry . . .
Americas
Ukraine, US sign Model 1 FATCA agreement
Ukraine and the US have signed a Model 1 FATCA intergovernmental agreement (IGA) according to an . . .
Africa
UK signs tax treaties with Colombia and Lesotho
The UK’s HM Revenue & Customs has announced that the UK has signed tax treaties . . .
Americas
Italy issues more tax guidance on controlled foreign companies
Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses guidance issued by the Italian tax authority on September 16 that provides important details on how to determine if Italy’s controlled foreign company (CFC) tax rules will apply . . .
Americas
Americas
Americas
Canada updates procedures for obtaining tax rulings and technical interpretations
The Canada Revenue Agency on April 22 released a new circular describing procedures to obtain an advance income tax ruling . . .
Europe
Apple, Google, Fiat, IKEA, McDonald’s reps to be grilled on tax avoidance by EU Parliament committee
Representatives of large multinationals will again defend their companies’ tax avoidance practices before an EU parliamentary committee. This time, Apple, Google, Fiat, IKEA. . .
Americas
Americas
Canada and Taiwan sign tax agreement, text available
Taiwan and Canada have signed an arrangement to avoid double taxation, Canada’s Department of Finance announced today. The . . .
Americas
US IRS releases guidance on foreign tax refunds received by RICs
The US IRS on January 11 released Notice 2016-10, describing regulations Treasury intends to release relating to the treatment under sections 853 and 905(c) of foreign tax refunds . . .
Americas
US Senators urge Treasury to consider retaliatory EU tax in response to State aid cases
Four influential US Senators have urged the Obama administration to examine whether it should use its regulatory authority to impose additional taxes on EU citizens and corporations in retaliation for EU State aid . . .
Americas
Africa
Ireland tax treaty update: agreements with Zambia, Germany, Luxembourg enter into force; pacts with Ethiopia, Pakistan ratified; new treaty with South Africa under negotiation
Ireland’s tax treaty with Zambia and protocols to tax treaties with Germany and Luxembourg have entered into force and effect, Irish Tax and Customs. . .
Americas
Americas
Stanford fellow examines US tax and non-tax effects of corporate inversions: Cathy Hwang / SSRN →
The New Corporate Migration: Tax Diversion Through Inversion, by Cathy Hwang. See: SSRN.
Americas
Americas
Americas
Amanda Varma promoted to tax partner at Steptoe
Steptoe & Johnson, on January 4, announced that tax attorney Amanda Varma has been been promoted to . . .
Africa
US IRS adds foreign base company income issue to private ruling “no rule” list, updates private letter ruling procedures
The US IRS has released its annual “no rule” list, adding foreign base company income issues to the list of topics that the agency will “not ordinarily” address in private letter rulings . . .
