The Business Roundtable, an association of US company CEOs, on March 11 released a PWC report it commissioned which concludes that the US’s high tax rate coupled with its worldwide system of taxation disadvantages US businesses in the global cross-border mergers and acquisitions market, leading to foreign takeover of US businesses . . .
The Obama administration, in its FY 2016 Budget, has proposed a minimum tax on US multinational corporation foreign income and a one-time14 percent tax on previously untaxed foreign deferred profits. Inversion transactions and earnings stripping were also among the targets of the $4 trillion FY 2016 budget . . .
The US IRS on January 12 announced that its international data exchange service (IDES) website is open for enrollment. Financial institutions and host country tax authorities use IDES to electronically send information reports on financial accounts held by US persons to the IRS under the FATCA or pursuant. . .
International corporate tax lawyer Elan P. Keller has joined Kaye Scholer’s New York office as a partner, the firm announced January 5. Keller, a lawyer and a CPA, is formerly with Caplin & Drysdale and, prior to that, with Macquarie Holdings, Inc. See, release.
The US IRS on December 17 released a draft version of the FATCA International Data Exchange Services (IDES) user guide. The draft discusses data preparation procedures and reporting. A final version of the guide will be available January 2015. See, IDES user guide
Dallas-headquartered tax firm Ryan announced November 11 that it will acquire WTP Advisors, a Minneapolis-based international tax and transfer pricing firm. See, Ryan release.
McKesson Corp., which is appealing an adverse decision in a transfer pricing dispute in Canada’s Federal Court of Appeal, filed a motion to amend its appeal on November 3 claiming that actions taken by the trial judge in filing a lengthy “Reasons for Recusal,” gave McKesson additional grounds for appeal, writes Timothy Fitzsimmons of Dentons in a . . .
In an October 24 letter, William J. Sample, Chair, Taxation Committee of the United States Council for International Business (USCIB) states that if adopted, the UN’s proposed modification to the commentary to Article 9 of the UN Model will lead to increased disputes and double taxation. Sample condemned the lack of input by stakeholders in the UN process and argues that is inappropriate for non-OECD countries that participated in OECD transfer pricing guideline negotiations and obtained concessions to “undercut” those negotiations by arguing elsewhere for positions that were rejected. USCIB
Related article:
The US Senate Finance Committee’s top Republican, on July 22, said that he would consider supporting legislation to stop corporate inversions, independent of comprehensive tax reform, as long conditions were met. . . .
The Dominican Republic will soon modify its transfer pricing regulations through publication of Executive Decree 78-14, reports EY. Read More: EY.
US and Armenian officials will discuss the possibility of entering into negotiations to update their 1973 double tax treaty during the annual US-Armenia Economic Task Force meeting scheduled for . . .
The US IRS on April 23 issued proposed regulations (REG-108214-15) defining the terms “active conduct” and “insurance business” for purposes of determining when a foreign insurance company’s income is excluded from the definition of passive income under section 1297(b)(2)(B). The regulations . . .
UPDATE: See, also PWC.
Luxembourg Finance Minister Pierre Gramegna on March 11 signed tax treaties with representatives of Hungary and Uruguay while attending an Ecofin meeting . . .
The UK’s HM Revenue and Customs on October 13 launched an online FATCA guide to assist UK financial institutions in registering and reporting financial information on behalf of their US customers in accordance with UK-US legislation. HMRC
Kathryn Keneally will join DLA Piper’s global tax practice in October and will be based in the firm’s New York office. Keneally served as Assistant Attorney General for the Tax Division of the US Department of Justice from 2012–2014. Release
The U.S. IRS and Caterpillar, Inc., on July 31, filed a stipulated settlement, ending their U.S. Tax Court dispute over whether royalty income should be allocated to Caterpillar from the company’s Belgium and French subsidiaries. Tax Court Docket No. 010790-13, For analysis of the dispute, see post by Jerald David August of Fox Rothschild, LLP.
Pfizer Inc.’s attempted takeover of British pharmaceutical rival, AstraZeneca, if successful, could yield a massive loss to the U.S. Treasury as its offshore profits could permanently escape taxation. See, Jessie Drucker and Zachary R. Mider, Bloomberg; Richard Murphy, Tax Research U.K.; Liz Hoffman, Wall Street Journal; Jia Lynn Wang. Washington Post; Matthew Herper, Forbes
VAT refunds owed Procter & Gamble, Unilever, and Colgate totaling hundreds of millions of dollars were withheld by the Mexican government while the companies were under investigation for tax avoidance, writes Henry Romero of Reuters in a September 1 article. See: Reuters.
New frequently asked questions (FAQs) were posted to the US IRS’s FATCA website on March 24 concerning reporting deadlines and nil reporting. . .
Ireland’s Minister of Finance Micheal Noonan on March 11 signed an order to commence legislation that establishes the Irish collective asset-management vehicle (“ICAV”), a new Irish corporate vehicle for investment funds. The ICAV will be a corporate entity with . . .
The US has released the text of an agreement signed by competent authorities of the US and Kazakhstan which concerns the eligibility of entities that are treated as fiscally transparent under a double tax agreement signed by the countries
. . .
An Australian Taxation Office (ATO) official, on May 22, confirmed that Australia and five other nations are collaborating to investigate the global tax planning of multinationals operating in the e-commerce industry.
Mark Konza, ATO Deputy Commissioner, International, said that Australia was “currently involved in a cooperative compliance approach” with five other nations. The collaboration led to the production of an
Rep. Charles Boustany (R-La.) will head of the tax policy subcommittee of the Ways and Means Committee of the US House of Representatives . . .
Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
The British Virgin Islands International Tax Authority on March 20 released guidance notes designed to provide practical assistance entities and their directors, officers, and advisers in complying with obligations under FATCA. See, FATCA Guidance, Version 2.0
US Senator Marco Rubio (R., Fla.), a likely 2016 Republican presidential candidate, and Senator Mike Lee (R., Utah) on March 4 released a tax plan that includes a proposal to adopt a territorial tax system. The Rubio-Lee plan would also . . .
Diana L. Wollman, former IRS director of international strategy in the Large Business and International Division, will join Cleary Gottlieb’s tax practice in New York as a partner where she will focus on tax controversy . . .
The Canadian government on January 7 announced that launch of the Canada Revenue Agency’s (CRA) Electronic Funds Transfer (EFT) initiative, which effective January 1, requires financial intermediaries, including banks, to report to the CRA incoming and outgoing international EFTs of $10,000 or more. The. . .
The Isle of Man on December 15 published revised Guidance Notes relating to intergovernmental agreements to improve international tax compliance signed in 2013 with the UK and US. Release.
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
The US IRS on October 27 released new questions and answers on the FATCA International Data Exchange Services (IDES) system on its website and listed approved certificate authorities.
The new Q&As are as . . .
The US Treasury Department has updated its FATCA website, reporting that Brazil has signed a Model 1 intergovernmental agreement (IGA) with the United States as of Sept. 23. Agreement
The European Court of Justice, in Kronos International Inc. released Sept 11, has ruled that a US registered company resident in Germany may assert that German tax rules violate free movement of capital, but the company may not claim freedom of establishment rights. The ECJ went on to reject the company’s contention that Germany’s tax rules in effect at the time, which permitted a set off for . . .
Hein & Associates LLP, on August 12, announced that Stephen T. Williams will be joining the firm’s Denver office as National Director of International Tax Services. Williams is formerly with PwC, Calgary. Release
Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.
