Americas
Americas
Americas
BRIC countries pledge to work together to stop tax avoidance and evasion
The BRIC countries of Brazil, Russia, India, and China have agreed to strengthen cooperation in areas such as transfer pricing and automatic exchange of financial account information to jointly crack . . .
Americas
US weighing changes to draft model tax treaty provisions, negotiating new treaty with Luxembourg
The US is considering changes to draft US Model Income Tax Convention provisions released last May, including several changes to provisions that deny tax treaty benefits to related party payments that are subject to a special tax regime (STR) . . .
Americas
US releases proposed regulations requiring country-by-country reporting by MNEs
The US IRS on December 21 released proposed regulations requiring annual country-by-country reporting . . .
Africa
Singapore’s tax treaties with Ecuador, San Marino, and Seychelles enter into force
Singapore’s Ministry of Finance on December 18 announced that tax treaties signed by Singapore and Ecuador . . .
FATCA/CRS
US posts two new FATCA FAQs
The US has posted new frequently asked questions (FAQs) to its FATCA website regarding registration for nonreporting financial institutions in Model 1 IGA jurisdictions and self-certifications on similarly agreed forms . . .
Africa
Developing nations detail their experiences with BEPS, react to OECD work
Tax officials from 11 developing nations described the most common practices MNEs use to shift profits out of their countries, obstacles that prevent their countries from stopping these practices, and their reactions to the OECD/G-20 base erosion profit shifting (BEPS) project, responding to a UN request for . . .
Americas
US IRS requests comments on compliance burdens associated with stock options under transfer pricing regs
The US IRS, on August 7, has requested public comments on the information collection requirements related to compensatory stock options under section 482 transfer pricing regulations . . .
Canada
UK and Canada agree to details of arbitration clause in tax treaty, text available
Canada and the UK have signed an agreement specifying the procedures for arbitration of tax disputes between the two nations, Canada’s Department of Finance . . .
Americas
US lawmakers to hold hearings on BEPS, EU State aid cases
(Updated 11/25/2015) The US Senate Finance Committee will consider the OECD/G20 base erosion profit shifting (BEPS) project and the European Commission’s State aid challenges to private tax rulings entered into between EU States . . .
Americas
Americas
Too big to tax? Vanguard and the arm’s length standard – Reuven S. Avi-Yonah / SSRN
Professor Reuven S. Avi-Yonah of Michigan Law School argues that the US IRS could launch a successful transfer pricing challenge to the fee arrangement between Vanguard’s investment manager company and its related mutual fund companies. See: SSRN.
Americas
Americas
US and Philippines sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that the Philippines has signed a Model 1 intergovernmental agreement (IGA) with the United States as of July 13. . .
Americas
Wyden bill would modify US PFIC rules for offshore reinsurance – PwC
A bill introduced by Senate Finance Committee Member Ron Wyden (D-Ore) to amend US passive foreign investment company (PFIC) rules would clarify the active insurance exception but could also create problems for companies that underwrite catastrophic risks, writes PwC in a June 29 analysis of the bill. See, PwC.
Americas
US and Croatia sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Croatia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of March 20. The text of the agreement is available. See: Model 1 IGA
Americas
US IRS updates FATCA IDES user guide, releases ICMM report notifications guides
The US IRS, on March 5, announced it has updated the FATCA international data exchange service (IDES) user guide to add user . . .
Americas
Edgar Klee joins Haynes and Boone’s Mexico City office
Tax lawyer Edgar Klee has joined Haynes and Boone’s Mexico City office as a partner, the firm announced March 2. Klee who is formerly with Turanzas, Bravo & Ambrosi, focuses on international corporate taxation. . .
Americas
Carbone joins Willkie Farr & Gallagher in New York
Anthony J. Carbone has joined Willkie Farr & Gallagher’s New York office as a partner, the firm announced January 20. Formerly co-leader of Bingham McCutchen’s tax group, Carbone focuses on US and international tax planning strategies and the tax consequences of business and investment transactions. See, release.
Americas
US IRS gives countries with “in substance” FATCA IGAs more time to sign IGAs, adds more countries to the “in substance” list
The US IRS on December 1 released an advance copy of guidance that provides that countries that have reached FATCA intergovernmental agreements (IGAs) “in substance” that do not sign an IGA by December 31 will continue to be treated as if an IGA was in effect as long as the country displays a “firm resolve” to sign an IGA as soon as possible. The new guidance . . .
Americas
Canadian Finance Minister tables tax measures
Finance Minister Joe Oliver on October 10 tabled in the House of Commons tax proposals to implement the government’s budget and about a dozen tax proposals not included in the budget.
International tax . . .
Americas
Americas
Americas
US signs first competent authority arrangements to implement FATCA IGAs with Australia and UK
The US IRS announced November 24 that it has signed competent authority arrangements (CCAs) with Australia and the UK to establish . . .
Americas
US IRS’s Heather Maloy to join EY
EY has announced that Heather Maloy, the IRS Commissioner for the Large Business & International (LB&I) Division, will join the firm’s national tax department as tax controversy . . .
Americas
Brazil modifies calculation of commodities transfer prices
The Brazilian Federal Revenue Department on June 8 issued Normative Instruction 1568/15 modifying the calculation of transfer prices based on Brazilian commodities methods applicable to imports and exports, writes PwC in a tax alert. See, PwC.
Americas
BMC Software wins US dividend repatriation case on appeal
The US Court of Appeals for the Fifth Circuit has ruled, in BMC Software Inc., decided March 13, that accounts receivables created under a transfer pricing closing agreement are not a related-party loans causing partial disallowance of the . . .
Americas
US IRS proposes to modify next-day rule for companies joining or leaving consolidated groups
The US IRS on March 6 published proposed regulations (REG-100400-14) modifying rules that determine how to report a company’s items of income and deduction that occur on the day the company joins or leaves a consolidated group. The proposal would alter regulations . . .
Americas
US IRS publishes regs on alternative simplified credit election for research
The US IRS on February 27 published final regulations (TD 9712) on electing the alternative simplified credit under section 41(c)(5) of the Internal Revenue Code. Section 41(a) provides an incremental tax credit for increasing research activities based on a percentage of a taxpayer’s qualified research expenses . . .
Americas
Colombian tax reform includes wealth tax on foreign companies
Colombia’s president has signed into law a tax reform package which includes a temporary annual tax on wealth in excess of $1 billion pesos (USD 425,000) held by domestic or foreign legal entities, writes PwC in a December 28 tax alert. The tax package also includes increases in income tax withholding rates . . .
Americas
Troy K. Lewis to head AICPA Tax Executive Committee
The American Institute of CPAs (AICPA) announced on October 22 that it has appointed Troy K. Lewis chairman of its Tax Executive Committee. Lewis is vice president and chief enterprise risk management officer at Heritage Bank in St. George, Utah and is the sole proprietor of Lewis & Associates, CPAs, LLC based in Draper, Utah. Release
Americas
Arthur Andersen name revived as WTAS changes its name to Andersen Tax
WTAS, a firm founded 12 years ago by members of now-defunct accounting firm Arthur Andersen, has renamed itself Andersen Tax. Andersen Tax will be a member of a newly created international entity called Andersen Global.
The firm has 17 offices in the US and locations in Switzerland, Russia, France, Italy, and The Netherlands. Release
Americas
US adds transfer pricing risk allocation guidance to list of priority tax projects
The US IRS, on August 26, released its 2014–2015 priority guidance plan, which details the tax guidance it intends to work on from July 2014 through June 2015.
Notable international tax changes . . .
Americas
IRS updates FATCA Withholding Foreign Partnership and Withholding Foreign Trust agreements
The U.S. IRS, on August 8, released Rev.Proc. 2014-47, which updates the Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) agreements for foreign partnerships and trusts that seek to enter into a WP or WT withholding agreement with the IRS under reg. section 1.1441-5(c)(2)(ii) and (e)(5)(iv). The new agreements replace agreements found in Rev. Proc. 2003-64, 2003-2 C.B. 306. Rev. Proc. 2014-47
Americas
US and Czech Republic sign Model 1 FATCA IGA
US Treasury Department has updated its FATCA website, reporting that the Czech Republic has signed a Model 1 intergovernmental agreement (IGA) with the United States as of August 4. Agreement
Americas
Remuneration of Canadian resident employee working in Australia subject to Australian tax because of employer’s deemed PE, says ATO
The Australian Taxation Office has ruled, in a May 30 interpretative decision. . .
Americas
Pfizer/Allergan merger plan highlights need for US anti-inversion legislation, say Professors Avi-Yonah and Marian: SSRN→
See: Inversions and Competitiveness: Reflections in the Wake of Pfizer/Allergan by Reuven S. Avi-Yonh and Omri Y. Maria: SSRN.
Americas
Americas
