Americas

Americas

Washington State tax subsidies to Boeing challenged by EU

December 26, 2014

The European Commission on December 19 requested formal consultations with the US in the World Trade Organization (WTO) concerning recent Washington State legislation extending tax subsidies to Boeing and other aerospace firms from 2024 through 2040, estimated at USD 8.7 billion. The Commission maintains that Washington State tax subsidies, originally set to expire in 2024, have already been declared WTO inconsistent. See, EU Commission release.

Americas

Whistleblower alleges that Valeant should continue to pay U.S. tax after inversion

August 25, 2014

Canadian billionaire Eugene Melnyk has confirmed that, in 2012, he made a presentation to U.S. tax authorities as an “official whistleblower,” alleging that Valeant Pharmaceuticals, formerly a U.S. company, should have continued to pay U.S. tax following its merger with Canada-based Biovail and change of headquarters to Canada, writes Nicolas Van Praet of the Financial Post. See, Financial Post.

Americas

Maruca rejoins Covington & Burling

August 4, 2014

Sam Maruca, former IRS Director of Transfer Pricing Operations for the Large Business and International Division, has rejoined Covington & Burling’s Washington, D.C. office as a partner. Maruca spent three years with the firm before joining the IRS in May 2011. Release

Americas

China and US agree in substance on FATCA IGA

June 26, 2014

US Treasury Department has updated its FATCA website, reporting that China has reached an “agreement in substance” on a Model 1 intergovernmental agreement (IGA) with the United States and consented to this status as of June 26.

Americas

Jeb Bush tax plan calls for territorial tax system, deemed repatriation of existing overseas profits

September 9, 2015

US presidential candidate Jeb Bush unveiled his tax plan in The Wall Street Journal on September 8, proposing a 20 percent corporate tax rate, limits on tax deductions, and a move to a territorial tax system coupled with “a one-time tax of 8.75%, payable over 10 years, on the more than $2 trillion in corporate profits sitting overseas.” See: The Wall Street Journal.

Americas

India/US transfer pricing deal anticipated

January 23, 2015

The India expects to sign an agreement with the US on Sunday that sets out a framework to resolve mutual agreement procedure disputes concerning the appropriate markup to apply to related-party transactions, and hopes to sign similar agreements with the UK, France, and other European nations, writes Jayshree P. Upadhyay of Business Standard in a January 24 article, quoting an unnamed tax official. See, Business Standard.