United States–MNE Tax

The US Senate on July 16 ratified a protocol to the US-Spain tax treaty (Treaty Doc. 113-4), the first US ratification of a tax treaty or tax treaty protocol since 2010. The protocol . . .

Americas

US, Monaco negotiating agreement for exchange of country-by-country reports

July 1, 2019

The US today announced it is negotiating a competent authority agreement . . .

Americas

Altera files Ninth Circuit petition for rehearing in challenge to US cost-sharing regulations: Steve Dixon / Miller & Chevalier→

July 25, 2019

Americas

House Ways and Means lawmakers urge US response to France’s digital tax proposal

June 20, 2019

US House Ways and Means Committee members . . .

Americas

US-Dominican Republic FATCA agreement enters into force

July 25, 2019

The US Treasury has announced on its website that the US-Dominican Republic Model 1 FATCA intergovernmental . . .

Americas

US announces probe into France’s digital services tax

July 10, 2019

The US will investigate whether France’s digital services tax, expected to pass the Senate . . .

Americas

US MNEs reversing inversions, less likely to invert in the first place, because of 2017 tax changes: Richard Rubin & Jared S. Hopkins / WSJ→

August 1, 2019

Americas

IRS issues final partnership regs on allocation of creditable foreign taxes

July 25, 2019

The US IRS on July 24 published final regulations . . .

Americas

US Senate Foreign Relations Committee approves tax treaty protocols with Japan, Luxembourg, Spain, Switzerland

June 25, 2019

Tax treaty protocols amending US tax treaties with Japan, Luxembourg . . .

Americas

US urging market countries to accept only modest changes to international tax system

June 6, 2019

The US is urging countries to agree to new international tax rules that would allocate a limited amount of additional profit and related taxing rights to countries where a multinational’s customers or digital users reside. In exchange for these additional taxing . . .

Americas

US IRS publishes final section 956 regs applicable to US corporate shareholders

May 23, 2019

The US IRS today published final regulations that provide a mechanism to exclude corporations . . .

Americas

Corporate veil dropping: British crown dependencies make beneficial ownership registers public, US takes baby steps

June 24, 2019

Virginia La Torre Jeker, J.D., a US tax practitioner located in Dubai, discusses June 19 announcements of Jersey, Guernsey, and the Isle of Man about plans to make beneficial ownership registers for legal entities public and US legislation proposed June 11 in this area . . .

Americas

In letter, US Senators Grassley and Wyden urge Treasury to use “all available tools” including Section 891, to stop France from enacting a DST: US Senate Committee and Finance→

June 24, 2019

Americas

US strikes deal with Mexico, suspends tariffs on Mexican goods: David Jackson / USA Today→

June 10, 2019

Americas

US IRS investigating Uber’s 2013–14 transfer pricing position: Giles Turner / Bloomberg→

June 4, 2019

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Americas

US IRS releases proposed PFIC regs, withdraws 2015 regs on insurance exception

July 10, 2019

The US IRS today released proposed regulations under sections . . .

Americas

US Senate to consider Chile, Hungary, Poland, Japan, Luxembourg, Switzerland tax treaty protocols: Bloomberg Tax→

June 18, 2019

Americas

First Look: US IRS issues final GILTI regulations, proposed DRD regs

June 16, 2019

The US IRS on June 14 released final and proposed regulations on the global intangible low-taxed income (GILTI) regime of section 951A, a key part of the 2018 Tax Cuts and Jobs Act. . .

Americas

Rand Paul to introduce amendments to four tax treaty protocols under US Senate consideration: Isabel Gottlieb & Kaustuv Basu / Bloomberg Tax→

June 24, 2019

Americas

US IRS corrects section 987 foreign currency regs

July 1, 2019

The US IRS today made corrections to final . . .

Americas

France seeks to reach digital tax deal with US at August G7 meeting, French minister says: The Local→

July 29, 2019

Americas

White House weighs indexing capital gains to inflation through executive order or rule change, sources say: Saleha Mohsin / Bloomberg→

June 27, 2019

Americas

First look: Altera reversed on appeal, US cost sharing regs are valid

June 9, 2019

The United States Court of Appeals for the Ninth Circuit on Friday reversed the Tax Court’s decision in Altera, finding that . . .

Americas

US IRS large business unit to identify audit targets using data analytics

May 16, 2019

The US IRS today announced that its Large Business & International (LB&I) division will begin making . . .

Americas

US IRS notes updates to country-by-country reporting instructions

July 10, 2019

The US IRS today notified taxpayers that that updated . . .

Americas

US IRS large business unit withdraws cost sharing arrangement directive

June 12, 2019

The US IRS’s Large Business and International Division in a notice published June 4, but dated and effective May 21, has announced . . .

Americas

American Bar Association tax section comments on proposed BEAT regulations→

May 16, 2019

Americas

USCIB worries that UN Practical Manual’s discussion of capital structures in new financial transactions appendix will lead to inappropriate recharacterization of debt vs equity: William J. Sample / USCIB→

July 22, 2019

Americas

Agreement reached on OECD transfer pricing guidelines for financial transactions, official says

June 8, 2019

Countries working on new OECD transfer pricing guidelines for financial transactions have reached agreement on virtually all issues associated with the project, The OECD’s Thomas Balco said June 4 at the 2019 OECD International Tax Conference. Balco also provided an update on other OECD transfer pricing projects, including the 2020 review of the country-by-country . . .

Americas

Proposed US tax regulations address real property exception for foreign pension funds

June 6, 2019

The US IRS today released proposed regulations (REG-109826-17) on the . . .

Americas

US to impose tariffs on all Mexican goods beginning July 1 unless Mexico assists in curbing illegal immigration: Steve Holland & Frank Jack Daniel / Reuters→

May 31, 2019

Americas

French Senate passes digital service tax despite US threat of potential retaliation, bill likely signed by Macron within two weeks: Liz Alderman / The New York Times→

July 11, 2019

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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