Americas
International tax reform and innovation box on agenda of new US House Ways and Means Chairman: Richard Rubin / Wall Street Journal→
For a WSJ interview of House Ways and Means Chairman Kevin Brady, see: The Wall Street Journal.
Americas
Americas
US signs Model 1 FATCA IGA with Montserrat
The US Treasury Department has updated its FATCA website, reporting that Montserrat has signed a Model 1 intergovernmental . . .
Americas
US Treasury should suspend work on regulations implementing country-by-country reporting say Ryan and Hatch
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 asking Treasury stop work on a regulation project to . . .
Americas
Canada signs 31 APAs in FY 2014/2015
Canada signed 31 advanced pricing arrangements (APAs) in FY 2014/2015, the most in five years, according to data released August 20 by the Canadian Revenue Agency (CRA). A total of 29 bilateral and 2 unilateral . . .
FATCA/CRS
US IRS publishes updated FATCA IDES user guide, puts data preparation examples on Github
The US IRS on April 20 announced it has updated the FATCA International Data Exchange Service (IDES) user guide to include enhancements for reporting. . .
Americas
Canadian guidance addresses use of multiple year data in transfer pricing
The Canadian Revenue Agency (CRA) has issued guidance on the use of multiple year data in determining the arm’s length price in transfer pricing cases. The guidance also address the use of statistical tools . . .
Americas
US and Qatar sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Qatar has signed a Model 1 intergovernmental agreement (IGA) with the United States as of January 7. The text of the agreement is available. See, agreement.
Americas
Ray Beeman joins EY
EY announced November 19 that Ray Beeman, former adviser to Chairman of the House Ways and Means Committee Dave Camp, has joined Ernst & Young’s National Tax Department in Washington, DC. As Tax Counsel and Special Adviser for Tax Reform, Beeman developed discussion drafts related to international tax, financial products, and pass-throughs. He also helped prepare The Tax Reform Act of 2014, released by Chairman Camp in February. See, EY release.
Americas
US posts new FATCA Q&A on searching branch name and GIIN on FFI list
A new FAQ was posted on the US IRS’s FATCA website on October 27 in the Branch/Disregarded Entity category. The FAQ . . .
Americas
Decision imminent on anti-inversion policy, says US Treasury official
The Obama administration will decide “in the very near future” whether it should exercise its regulatory authority to make corporate inversions less economically attractive, US Treasury Secretary Jacob Lew said on Sept. 8.
Speaking at the Urban Institute in Washington, Lew said that . . .
Americas
US and Latvia sign Model 1 FATCA IGA
US Treasury Department has updated its FATCA website, reporting that Latvia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 27. Agreement
Americas
Singapore/Barbados treaty enters into force
Singapore’s agreement with Barbados for the avoidance of double taxation entered into force on 25 April 2014. Release
Americas
Americas
Americas
US IRS releases guidance to tax agents on intangible property licenses and deemed annual royalty income
The US IRS today released to the public two more international practice . . .
Americas
Japan’s Supreme Court says Delaware limited partnerships are corporations for tax purposes
Masao Yoshimura, an Associate Professor of Tax Law at Hitotsubashi University’s Graduate School of International Corporate Strategy, analyzes a July 17 decision of the Supreme Court of Japan concluding that Delaware limited partnerships should be classified as corporations for tax purposes . . .
Americas
Irish Revenue outlines FATCA treatment of holding companies and treasury companies
Irish Revenue on June 17 released guidance on the treatment of holding companies and treasury companies for purposes of FATCA reporting, in light of updated US IRS guidance . . .
Americas
Text available of TIEA between Ireland and the Bahamas
Irish Tax and Customs on May 1 released the text of a tax information exchange agreement signed by Ireland and the Bahamas. The agreement . . .
Americas
US Senator slams Business Roundtable members’ use of tax havens, identifies companies that pay little tax
Of the 201 CEOs that make up the membership of the Business Roundtable, 111 lead US companies that use offshore tax havens, and many lead companies that pay little or no corporate tax despite being profitable, according to a report by ranking member of the US Senate Budget Committee, Bernie Sanders (I-Vt.), released . . .
Americas
US IRS provides details on FATCA IDES, Forms W-8 and W-9
The US IRS on December 11 added new information on its website on the FATCA International Data Exchange Service (IDES). The IRS describes the IDES enrollment process, lists compatible web browsers . . .
Americas
OECD official discusses “double Irish” and US reaction to BEPS with The Irish Independent
Pascal Saint-Amans, the director of the OECD Centre for Tax Policy and Administration, addressed Ireland’s recent tax announcements and his views on whether the US will implement or block the OECD/G-20 base erosion profit shifting measures during an interview with the Irish Independent. See, Irish Independent.
Asia-Pacific
United Arab Emirates and Barbados sign tax treaty
The United Arab Emirates and Barbados, on Sept. 26, signed an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement emphasizes the desire of both countries to avoid double taxation on the income of individuals and companies, commercial sea and air transport, and on other similar taxes. Release
Americas
US official says some countries want conditions placed on access to BEPS project’s country-by-country reporting data
Countries negotiating the OECD/G-20 base erosion profit shifting (BEPS) guidance have advanced a proposal to require countries that seek access to country-by-country reporting data to first to agree to enhanced dispute resolution, a US Treasury official said on Sept 17.
Speaking during a Deloitte webinar, Robert Stack, US Treasury Deputy . . .
Americas
Law firm reports on U.S. Mulitstate Tax Commission’s transfer pricing meeting
Sutherland Asbill & Brennan LLP has provided a report of a July 28 meeting of the Multistate Tax Commission’s Arm’s Length Adjustment Services Advisory Group, which is creating a transfer pricing model for the U.S. states and is considering ways to improve the states’ ability to analyze intercompany transactions. See, Sutherland SALT report.
Americas
Ireland releases guidance on FATCA compliance
Ireland’s Revenue Commissioners, on June 30, released guidance on compliance by Irish entities with their obligations under U.S. FATCA provisions. See, Financial Accounts Reporting (United States of America) regulations 2014 (PDF, 179KB).
Americas
Russian law permits banks to send information to US to meet FATCA requirements
A Russian law, signed June 30, gives financial institutions the right to pass information about U.S. taxpayers to the IRS to satisfy FATCA requirements, but only after first sending the information to Russian authorities and only if the taxpayer gives permission for the information transfer, reports Delphine d’Amora of The Moscow Times.
Americas
UAE and US agree in substance on FATCA IGA
The United Arab Emirates and the United States, on June 10, agreed in substance to a Foreign Account Tax Compliance Act (FATCA) intergovernmental agreement (IGA), according to reports from the Abu Dhabi City Guide and the Khaleej Times.
Americas
Australia, US sign FATCA intergovernmental agreement
The agreement was signed in Canberra on 28 April. U.S. Government Press Release
Americas
USCIB sees flaws in draft US model tax treaty
The United States Council for International Business has written to US Treasury, arguing that draft provisions in the US model tax treaty released last May “tilt too far in their attempt to prevent inappropriate claims of treaty benefits.” The group is concerned with provisions on special regimes, subsequent changes in law, and limitation on benefits. See: USCIB. Related: MNE Tax.
Americas
IRS regs extend section 956 antiabuse rules to partnership transactions, address FPHCI exception for active rents and royalties
The US IRS on September 2 released temporary and proposed regulations on the application of the section 956 deemed dividend rules to partnership transactions. Regs were also issued providing that a controlled foreign corporation (CFC) must conduct relevant activities itself to take advantage of the foreign personal holding company income (FPHCI) active rent and royalties exception, including in situations where a cost sharing . . .
Americas
US proposes to modify tax regulations specifying when individuals are residents of US possessions
The US IRS on August 27 released proposed amendments to regulations that would make more flexible the tests for determining whether an individual is a resident of a US territory . . .
Americas
Thomas H. Young joins McDermott’s Chicago tax practice
Thomas H. Young has joined McDermott Will & Emery’s US and international tax practice group as a partner based in Chicago, the firm has announced. Young is formerly a senior manager of international tax at KPMG LLP, where . . .
Americas
US and Curacao sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Curacao has signed a Model 1 intergovernmental agreement (IGA) with the United States as of December 16, 2014. The text of the agreement is available. See, agreement.
Americas
Michael Lebovitz and Stephen Weerts join White & Case
Michael Lebovitz and Stephen Weerts have joined White & Case’s Los Angeles office, the firm announced January 5. The lawyers, both formerly with DLA Piper, will work on legal and tax aspects of international joint ventures, cross-border mergers and acquisitions, and international corporate finance and capital markets transactions. See, White & Case release.
Americas
US announces expanded transition relief for FATCA withholding and information reporting
The US IRS on October 10 released an advance copy of Notice 2014-59, expanding transition relief provided in Notice 2014-33 to withholding agents, foreign financial institutions, and payors that have withholding or information reporting requirements respect to accounts and obligations they open or enter into before January 1, 2015. See, Notice 2014-59
Americas
Firm reports on US Multistate Tax Commission transfer pricing meeting
Sutherland Asbill & Brennan LLP has provided a detailed account of an October 6 meeting of the US Multistate Tax Commission’s Arm’s Length Adjustment Services Advisory Group, where seven external economic firms provided advice on ways the MTC could assist states with their transfer pricing challenges. For detailed discussion, see Sutherland Asbill & Brennan.
Americas
FATCA challenged in Canadian court and United Nations
Two Canadian-U.S. dual citizens, on August 11, filed suit in the Federal Court of Canada challenging the constitutionality of the intergovernmental agreement signed by the U.S. and Canada that implements FATCA.
The lawsuit, funded by the Alliance for the Defense of Canadian Sovereignty (ADCS), alleges that the intergovernmental agreement violates provisions of the Canadian Charter of Rights and Freedoms . . .
Americas
Americas
U.S. and Haiti agree in substance on FATCA IGA
U.S. Treasury Department has updated its FATCA website, reporting that Haiti 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 30.
