An Australian law to give effect to the FATCA intergovernmental agreement between Australia and the United States received royal assent on June 30. For the text and history of the law, see: Tax Laws Amendment (Implementation of the FATCA Agreement) Bill 2014. For more analysis, see King & Wood Mallesons
Sen. Rand Paul, a Kentucky Republican, and Sen. Harry Reid, a Nevada Democrat, are advocating for a one-time repatriation tax holiday for multinationals to replenish depleting federal highway funds, according to a June 9 article by Jonathan Weisman, New York Times.
The IRS has announced, in Notice 2014-32, that it will amend regulations under section 367 relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving one or more foreign corporations. Notice 2014–132 (27k). For analysis, see: Sally P. Schreiber, Journal of Accountancy; Deloitte; Bloomberg; KPMG
US Senate Finance Committee Chairman Orrin Hatch (R-Utah) in a July 16 letter requested that the US Government Accountability Office (GAO) conduct an analysis of the impact of the OECD/G20 base erosion profit shifting project (BEPS) on American . . .
G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .
UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .
The UK’s HM Revenue and Customs on May 21 issued guidance on the treatment of holding companies and treasury companies under FATCA, the multilateral competent authority agreement implementing the common reporting standard, and the . . .
The United Arab Emirates will complete and sign a Model 1 FATCA IGA this month and will send the agreement electronically to the US IRS in September 2015, UAE HE Younis Haji Al Khoori, Undersecretary of the Ministry of Finance told reporters February 15. The UAE had reached an agreement . . .
Singapore and the US on December 9 signed a FATCA Model 1 Intergovernmental Agreement (IGA), following the initialing of the agreement May 5, the Inland Revenue Authority of Singapore has announced. The IGA is designed to simplify FATCA information reporting for Singapore financial institutions. See, Singapore release.
The US IRS on October 15 posted a “recent development” to the TY2014 Instructions for Form 1042-S, as follows:
“The 2014 Form 1042-S posted to IRS.gov on 04/02/2014 supersedes the 2014 Form 1042-S posted to IRS.gov on 03/12/2014. We are re-posting this form to correct the formatting of the recipient’s address in order to facilitate the mailing of this form to taxpayers.” See, FATCA website.
South African Minister of Finance, Mr Nhlanhla Nene, and U.S. Ambassador to South Africa, Mr Patrick H. Gaspard, on June 9, signed an intergovernmental agreement to improve international tax compliance and to implement the Foreign Account Tax Compliance Act (FATCA). Release
US firm, Illinois Tool Works Inc, has petitioned Tax Court to challenge the IRS’s decision to recharacterize a loan from its Bermuda subsidiary to a US affiliate as a taxable repatriation of profits, writes Patrick Temple-West, Reuters.
Canada’s Federal Court of Appeals has affirmed the Tax Court’s ruling, in Canada v. Lehigh Cement Limited, that a taxpayer’s acquisition of shares in a a non-resident company did not result in avoidance of tax. In so doing . . .
The OECD has released a discussion draft on transfer pricing documentation and country-by-country reporting in response to action item 13 of the base erosion and profit shifting (BEPS) plan. Action 13 calls for a review of the existing transfer pricing documentation . . .
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