The Obama administration is open to negotiating the tax rates for its proposed global minimum tax and one-time tax on previously untaxed foreign deferred profits, US Treasury Secretary Jacob Lew said February 5. . .
Douglas Shulman was named senior executive vice president and global head of client service delivery (CDS) at BNY Mellon and has been appointed to the executive committee, the bank announced January 7. Shulman, 47, is formerly with McKinsey & Co., where he was a senior adviser . . .
The US IRS has posted an update to the instructions for Form 8966, FATCA Report, for 2014. The IRS states that the update “supplements the Instructions for Form 8966 to correct and clarify certain references to the reporting requirements of participating [foreign financial institutions] for the 2014 year, including to reflect a correcting amendment to section 1.1471-4(d)(7)(iv)(B) of the temporary chapter 4 regulations (TD 9657).” See, Update to the Instructions for Form 8966 for 2014
Mike Danilack, former IRS Deputy Commissioner (International) of the Large Business and International (LB&I) division, has joined PwC, the firm has announced. Danilack will serve as a principal in PwC’s Washington National Tax Services’ transfer pricing . . .
The Obama administration has announced that it has taken regulatory action to make it more difficult and less lucrative for US companies to invert.
The new rules, which apply to deals closed on Sept. 22 or thereafter, are designed to stop post-inversion planning techniques that allow . . .
The IRS and Treasury on Sept. 23 published a notice which describes regulations that will be issued with respect to inversion transactions. See, Notice 2014-52.
Justice Patrick Boyle has recused himself from deciding all remaining issues in McKesson Canada Corporation’s transfer pricing proceedings in the Tax Court of Canada, including costs and confidentiality issues . . .
Two US senators have announced that they will move to tighten tax laws that discourage corporate inversions, while a third believes that comprehensive US tax reform is key to preventing . . .
The US Treasury Department has updated its FATCA website, reporting that Angola and the US signed a Model 1 intergovernmental agreement (IGA) as . . .
In a September 25 letter, 24 international tax experts have urged the US Congress to reject legislative proposals calling for the adoption of a territorial tax system and for the immediate taxation US multinational . . .
New frequently asked questions (FAQs) were posted to the US IRS’s FATCA website on August 27 under the subheading “Field Level Errors” as . . .
The US IRS in Notice 2015-54 released August 6 announced that the government will issue regulations overriding section 721(c) nonrecognition treatment in cases where property is transferred by a US person to a partnership that has foreign partners related . . .
A US district court, in the case of Lehman Brothers Holdings Inc. v. US decided May 8, disallowed a US taxpayer’s claim for a foreign tax credit under the US-UK tax treaty for withholding taxes imposed on substitute dividend payments received by its wholly owned US subsidiary from its UK subsidiary pursuant to back-to-back stock loan transactions, EY writes in a May 19 tax alert. See: EY .
New frequently asked questions (FAQs) were posted to the US IRS’s FATCA website on May 8 covering technical issues associated with the FATCA International Data Exchange Service (IDES). The FATCA IDES is an electronic . . .
A new FAQ was posted to the FATCA website on December 22, as follows . . .
The United States Court of Appeals for the Second Circuit on November 5 upheld the US Tax Court’s decision in Barnes v. Comm., stating that the IRS properly applied the step transaction doctrine to disregard. . .
The Brazilian Revenue Service, in Declaratory Interpretative Act 07 (ADI 07/2014) released August 15, has modified its position concerning the tax treatment of amounts paid by a Brazilian residents to foreign legal entities for the provision of infrastructure for data processing and storage with remote access, deeming such payments to be payments for the provision of services, writes EY in an August 20 tax alert. For a discussion of the new guidance, see EY.
The U.S. Tax Court, in Amazon.com, Inc. & Subsidiaries v. Commissioner, has denied Amazon’s motion for partial summary judgement, concluding that there are genuine disputes of material fact necessary to determine to whether IRS abused its discretion in adjusting amounts under a cost sharing agreement . . .
The IRS updated the FATCA frequently asked questions and answers on July 23, providing . . .
FATCA frequently asked questions and answers have been posted to the IRS website. Topics include responsible officers, branches/disregarded entities and a registration update. FAQs
The US government is trying to persuade the EU Commission that it is inappropriate to require EU States to recover “retroactive” tax from multinationals upon a finding that illegal State aid was provided through overly-generous private tax rulings, Robert Stack . . .
Ken Brewer has joined Alvarez & Marsal Taxand’s international tax team in Miami as a senior advisor, the firm announced . . .
Former US Treasury Associate Tax Legislative Counsel, Alexandra Minkovich, has joined Baker & McKenzie’s Washington DC office as counsel, the . . .
US Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Chairman Paul Ryan (R-WI) today sent a letter to Treasury Secretary Jack Lew raising concerns about transfer pricing documentation requirements in the OECD/G20 base erosion and profit shifting (BEPS) plan and calling on the administration to consult . . .
The US Treasury Department has updated its FATCA website, reporting that Colombia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of May 20. The text of the agreement is available. See, Model 1 IGA.
The US IRS in private letter ruling 201514006 released April 3 has granted a taxpayer consent to change to the elective method and period-by-period identification for purposes of including stock based compensation as an intangible development cost that taxpayer must share for purposes of its cost sharing agreement. See, PLR 201514006.
The US on October 6 made changes to the FATCA registration system and published an updated version of the FATCA Registration Online User Guide. See, FATCA Registration Online User Guide (PDF 8.91MB), FATCA website
Singapore’s government has launched a public consultation on proposed regulations that would help financial institutions comply with the US Foreign Account Tax Compliance Act (FATCA). Singapore has substantially concluded a Model 1 Intergovernmental Agreement with the US, which will be signed in the fourth quarter of 2014. Release
Peter Baum has joined O’Connor Davies as tax partner, according to a May 19 press release. The public accounting firm has offices in New York, New Jersey, and Connecticut. Release
See: The Three Causes of Inversions: Reflections on Pfizer/Allergan and Notice 2015-79, by Reuven S. Avi-Yonah, University of Michigan Law School: SSRN
The Philippines Department of Finance on September 8 advised that since the FATCA intergovernmental agreement (IGA) between The Philippines and the US has not yet entered . . .
The US IRS on August 28 released IRS agent training materials on transfer pricing rules under section 482 and on foreign-to-foreign transactions under . . .
China has signed a tax treaty with Chile and a protocol to its tax treaty with Russia, China’s State Administration of Taxation said in July 3 English-language releases. The treaty with Chile, signed May 25, is is the 100th treaty signed by China, the government . . .
G7 finance ministers and central bank governors agreed at a meeting in Dresden held May 27–29 that the mechanisms used to settle tax disputes between nations need to be improved, German Finance Minister Wolfgang Schaeuble said. Schaeuble told a press conference following . . .
The Inland Revenue Authority of Singapore (IRAS) on April 17 updated information on its website concerning FATCA reporting. Changes were made to information on . . .
The Tax Court of Canada has concluded that TDL Group, a Canadian subsidiary of Wendy’s International Inc., the US restaurant chain, may not deduct $10 million (7.8 million USD) interest on loans from its parent in 2002. TDL used the loan to acquire additional shares of its wholly owned US subsidiary, Tim Donut US Limited, Inc., which then lent
Switzerland and Liechtenstein have agreed to the terms of a revised double tax treaty and expect to sign the agreement this summer, Switzerland’s Federal Department of Finance (FDF) announced on February 5. The agreement, which would replace . . .
The UK on January 13 released an updated schema and supporting documents for software developers working on the FATCA service . . .
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