Ecuador has adopted new tax measures curtailing tax deductions for transactions between related parties, including limits on expenses for royalties, technical services, and advisory services, writes EY in a February 27 report. The new law also eliminates a tax exemption for income derived from the sale of stock in Ecuadorian entities. See, EY.
The US IRS, on February 17, announced updates to the FATCA International Data Exchange Service (IDES) user guide, including a revised data preparation section and more instructions. The IRS also said that an IDES sample test file has been added to the IDES Data File Preparation page and has scheduled a FATCA IDES open testing session for financial institutions and tax . . .
Ireland may not support a proposal advanced by the UK and Germany to use a modified nexus approach to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting (BEPS) plan, Finance Minister Michael Noonan said December 2. The joint UK/German proposal, announced by the . . .
The U.S. IRS, on June 13, released the following private letter rulings (PLRs) that involve multinational entities
. . .
The US IRS has released its Transfer Pricing Audit Roadmap, which provides recommended audit procedures, links to reference materials, and insight into what to expect during a transfer pricing examination. See, Roadmap, release. For analysis, see KPMG, PwC
The UK’s HM Revenue and Customs (HMRC) on November 30 announced that it has changed its interpretation of the company residence tie breaker clause in the Jersey-UK tax treaty and in 15 other tax treaties that . . .
Germany had the greatest number of unresolved mutual agreement procedure (MAP) cases among OECD countries during the 2014 reporting period, according to OECD statistics . . .
The US on October 29 released seven international practice units. . .
Professor Allison Christians of McGill University provides an update of the lawsuit. See: Tax, Society & Culture. Related: MNE Tax.
The Indian government on September 4 updated the procedures that reporting financial institutions must follow to register and submit the Form 61B or nil statement for purposes of complying . . .
The US IRS on August 12 released guidance specifying new procedures to request assistance from the US competent authority under income tax treaties and to obtain an advance pricing agreement . . .
The IRS will not release an updated XML schema for FATCA reporting (Form 8966) for tax year 2015, the agency said August 10. In a new . . .
The US Treasury Department has updated its FATCA website, reporting that Iceland has signed a Model 1 intergovernmental agreement (IGA) with the US as of May 25 and that Romania has signed a Model 1 IGA with the US as of May 28. The text of the agreements are available. See, FATCA IGA with Romania, FATCA IGA with Iceland.
The UK on May 26 updated the schema and supporting documents for Foreign Account Tax Compliance Act (FATCA) software . . .
The US IRS on May 6 issued two revenue rulings that conclude that transactions amount to section 351 transactions followed by D reorganizations . . .
International tax provisions in the Canadian government’s budget 2015, released April 21, provide withholding tax relief to non-resident employers whose employees work in Canada for short periods of time and tighten an antiavoidance rule applicable to captive insurance . . .
Former US House of Representatives Ways and Means Committee Chairman Dave Camp (R-MI) has joined PwC as a senior policy advisor in its Washington National Tax Services practice, the firm announced . . .
The US IRS released updates to its frequently asked questions (FAQs) on the FATCA IDES system dated January 5. Under the “general questions” heading, the . . .
The US Tax Court in Securitas Holdings Inc. v. Comm., released October 29, has ruled that payments made under a brother-sister captive insurance arrangement were deductible insurance premiums because . . .
Canada’s Department of Finance has released proposed international tax legislation, including measures to implement the government’s 2014 budget, but said it decided to postpone action on anti-treaty shopping legislation.
The proposals, released on August 29, include amendments to Canada’s foreign affiliate dumping rules . . .
More analysis: KPMG
The U.S. Joint Committee on Taxation released a report on July 21 entitled “Present Law And Background Related To Proposals To Reform The Taxation Of Income Of Multinational Enterprises.” The report was prepared in connection with a Senate Finance Committee public hearing scheduled for July 22 on the taxation of cross-border income. Report, Prior coverage
The OECD’s Base Erosion and Profit Shifting (BEPS) initiative has increased tax controversies between nations and is likely to continue to do so in the future, Samuel Maruca, U.S. IRS Director of Transfer Pricing Operations said April 30.
“My fear is that some of our treaty partners view this as a license [and are] reaching out and helping [themselves] to the tax base,” said Maruca, who spoke during a webinar sponsored by EY. Maruca . . .
The IRS, in Notice 2014-31 released April 24, extended until 2016 Notice 2012-45, dealing with the treatment of government bonds under the passive foreign investment company (PFIC) rules. Notice 2014-31 (PDF 10K)
The US and India remain at loggerheads over the percentage of profit to be allocated to India subsidiaries of US IT and ITeS companies, with US pushing for a 12 – 13 percent rate and India unwilling to go below 18 percent, according to a an April 9 Financial Express article written by Santosh Tiwari. An unnamed official quoted by Tiwari suggested that “the way forward could be to tackle the existing cases at a higher rate and new cases at the rate closer to what the US wants.” Read More: Financial Express
The US Treasury Department has updated its FATCA website, reporting that Azerbaijan and the US signed a Model 1 intergovernmental agreement . . .
The US Treasury Department has updated its FATCA website, reporting that Portugal has signed a Model 1 intergovernmental agreement (IGA) with the United States . . .
The US IRS on April 3 issued final, temporary, and proposed regulations relating to the allocation of the credit for increasing research activities to corporations and trades or businesses under common control. See, TD 9717, REG-133489-13.
US Senate Finance Committee Chairman Orrin Hatch (R-Utah) and Ranking Member Ron Wyden (D-Ore.) have requested stakeholder input on US tax reform, including international tax reform. The goal is to provide input for five bipartisan Finance Committee working groups that . . .
Hareesh Dhawale has been appointed director of the US IRS’s advance pricing and mutual agreement (APMA) program in the Large Business and International Division, the IRS has announced. Dhawale has served as acting director of APMA since June 2014. APMA oversees the IRS’s advance pricing . . .
A new frequently asked question (FAQ) was posted to FATCA website on February 2 in the in “General Compliance” category, as . . .
William Alexander will join Skadden, Arps, Slate, Meagher, & Flom’s Washington, DC office, the firm announced January 8. Alexander, who has been with the IRS Office of Chief Counsel since 1990 and served as IRS associate chief counsel (corporate) for the last 12 years, will join Skadden’s global tax group . . .
The US Department of the Treasury’s Financial Crimes and Enforcement Network (FinCEN), on July 30, released proposed rules that would require banks and other financial institutions to learn and verify the identity of the beneficial owners of their legal entity clients . . .
Even though international agreements have been reached on combating tax avoidance through the OECD/G20 base erosion profit shifting (BEPS) plan initiative, it does not necessarily follow that US multinational . . .
US presidential candidate Donald Trump’s tax plan, unveiled September 28, includes proposals for a 15 percent tax rate on all business income, limits on interest deductions and other unspecified business deductions, a deemed repatriation of all overseas profits of US multinationals at a 10 percent rate, and an end to deferral. See: Trump plan. More: TaxVox, Fortune, Slate, Bloomberg, The Guardian, CNN, New York Times, Politico, Wall Street Journal.
US Treasury on May 20 released for public comment draft proposals that would significantly modify the US Model Income Tax Convention. Included are proposals to address stateless income, discourage corporate inversions, and permit expanded use of the treaty through a derivatives benefits rule. The next US model would also include a provision requiring dispute resolution . . .
The magnitude of profit shifting by American companies “may be significant,” a US Congressional Research Service (CRS) report has concluded. The report, released April 30, found that about 50 percent of the $1.2 trillion in overseas profit reported by American . . .
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