United States–MNE Tax

Americas

US makes additional corrections to regs (TD 9902) on income subject to a high rate of foreign tax: Federal Register→

December 11, 2020

Americas

US IRS corrects final regs (TD 9902) on income subject to a high rate of tax: Federal Register→

December 11, 2020

Americas

First Look: US publishes final and proposed PFIC regulations

December 7, 2020

The US on December 4 issued final (T.D. 9936) and proposed regulations . . .

Americas

US and Germany again agree to exchange country-by-country reports on large multinationals

December 4, 2020

The competent authorities of the US and Germany have issued a joint statement, agreeing . . .

Americas

A new EU-US joint agenda for global change should include fair taxation of digital economy, EU officials say: EU Commission→

December 2, 2020

Digital Economy

UN tax committee releases official report on outcome of 21st session: Committee of Experts on International Cooperation in Tax Matters→

December 2, 2020

Americas

France to request EU retaliation if US enacts trade sanctions in response to French digital services tax, Le Marie says: Reuters→

December 2, 2020

Americas

US and Monaco agree to exchange country-by-country tax reports on large multinationals

November 30, 2020

The US IRS today announced that the US and Monaco have agreed . . .

Americas

The US and Mexico’s transfer pricing approach for maquiladoras

November 30, 2020

Dr. J. Harold McClure, New York City, notes that the US’s announcement on November 16 that the US and Mexico have again agreed to renew their transfer pricing framework for US multinational enterprises that have maquiladora operations and discusses the appropriate arm’s length transfer pricing policies for maquiladoras . . .

Americas

France cancels suspension of digital service tax collection, sends Facebook, Amazon, other large tech firms tax bills due in December: Reuters→

November 25, 2020

Americas

Janet Yellen is Biden’s choice for treasury secretary: Ben White / Politico→

November 25, 2020

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Americas

A proposed transfer pricing safe harbor for US retailers

November 24, 2020

Dr. Ednaldo Silva of RoyaltyStat, Bethesda, MD, proposes that US state tax authorities allow US retailers to apply a safe harbor that defines the arm’s length operating profit markup based upon a formula . . .

Americas

US IRS prevails in Coca-Cola transfer pricing dispute over intercompany royalties

November 23, 2020

Dr. J. Harold McClure, a New York City economist, discusses the US Tax Court’s November 18 ruling in a transfer pricing dispute between the IRS and Coca-Cola which considered the appropriate evaluation of intercompany royalties . . .

First Look: US Tax Court rules in favor IRS in Coca-Cola transfer pricing dispute

November 19, 2020

The US Tax Court handed a big win to the IRS on November 18 in a transfer . . .

Americas

Blackrock prevails in UK transfer pricing dispute

November 18, 2020

Liz Hughes and Anthony Crewe, of Grant Thornton UK LLP, discuss a November 3 UK First-tier Tribunal decision in a transfer pricing dispute involving US-headquartered Blackrock investment management group . . .

United States

US IRS releases 2020-21 priority tax guidance plan: US Department of Treasury→

November 18, 2020

Americas

Carol Doran Klein retires from USCIB, Rick Minor takes over as tax lead: USCIB→

November 18, 2020

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Americas

US should amend tax rules providing that foreign funds that originate loans have effectively connected income because the policy if flawed and funds work around the rule anyhow, attorney argues: David S. Miller / Proskauer Rose LLP→

November 17, 2020

Americas

First Look: US and Mexico renew of competent authority agreement on Maquiladoras

November 17, 2020

The US IRS on November 16 announced that the US and Mexico have . . .

Americas

US IRS again corrects final regs (TD 9909) limiting deduction for dividends from foreign corporations: Federal Register→

November 16, 2020

Americas

US IRS invites the public to recommend guidance that should be rescinded, modified, or waived to assist businesses and individuals recover from economic effects of COVID-19 pandemic: Federal Register→

November 16, 2020

Americas

Chip Harter, US Treasury deputy assistant secretary for international tax affairs, to leave his post this month: Bernie Becker / POLITICO→

November 16, 2020

Americas

US IRS corrects final regs limiting deduction for dividends from foreign corporations: Federal Register→

November 13, 2020

Americas

US issues final and temporary regs on gain or loss from foreign persons from sale of partnership interests: Federal Register→

November 6, 2020

Americas

US IRS again corrects FDII and GILTI regs: Federal Register→

November 3, 2020

Americas

US IRS limits taxpayers’ ability to “telescope” results of MAP and APA negotiations into current tax year, requiring taxpayers to instead amend prior years’ returns: Internal Revenue Service→

October 29, 2020

Americas

Croatia to initiate tax treaty negotiations with the United States

October 28, 2020

Ksenija Cipek, Head of Tax Risk Analysis, Ministry of Finance, Tax Administration, Croatia, discusses the Republic of Croatia’s decision to initiate proceedings to conclude a tax convention with the United States. . . .

Americas

US corrects final FDII and GILTI regs: Federal Register→

October 28, 2020

Americas

Final US regs address absorption of NOL carryovers, carrybacks and update rules on consolidated groups that include life insurance and other companies: Federal Register→

October 27, 2020

Americas

US to terminate international shipping agreement with Hong Kong

October 20, 2020

The US IRS, in Announcement 2020-40, has advised that the . . .

Americas

France reinstates digital tax, courting trade war: Bjarke Smith-Meyer & Elisa Braun / POLITICO→

October 14, 2020

Africa

The Pillar One blueprint — the potential future of international taxation and transfer pricing

October 13, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP provide a detailed look at the report on the Pillar One blueprint, approved by the Inclusive Framework on BEPS and released by the OECD on October 12 . . .

Africa

Countries unable to agree on global tax overhaul, new blueprint reports released

October 12, 2020

An OECD-led coalition of 137 countries known as the Inclusive Framework on BEPS failed to reach agreement on a coordinated update to the international tax rules at their October plenary meeting, OECD . . .

Americas

US corrects final tax regs on income subject to a high rate of foreign tax: Department of Treasury / Federal Register→

October 9, 2020

Americas

US IRS issues final BEAT regulations: Department of Treasury→

October 9, 2020

Americas

US IRS issues final regs on withholding and information reporting for dispositions of partnership interests engaged in US trades or businesses: US Treasury→

October 8, 2020

Americas

New US IRS practice unit training materials address cost-sharing arrangements and stock-based compensation: US Department of the Treasury→

October 5, 2020

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin