United States–MNE Tax

Americas

US IRS releases final foreign currency regulations

May 14, 2019

The US IRS on May 13 published final tax regulations applicable to multinationals . . .

Americas

France should renegotiate FATCA unless US agrees to concessions aiding dual nationals, parliamentary report says: Gregory Viscusi / Bloomberg→

May 16, 2019

Americas

US proposed regs address withholding, reporting for partnerships with foreign partners

May 8, 2019

The US IRS on May 7 published proposed tax regulations (REG-105476-18) applicable to . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Americas

IRS guidance addresses new tax law’s limits on business interest deductions

April 2, 2018

The US IRS today issued guidance on the new cap on large businesses’ interest deductions, enacted in the Tax Cuts and Jobs Act in December 2017. The new rules . . .

Americas

US tax act’s amendments to CFC stock attribution rules change treatment of US private companies with foreign investment: EY→

February 6, 2018

Americas

First Look: US IRS releases proposed FDII regulations

March 5, 2019

The US IRS on March 4 released proposed foreign-derived intangible income or FDII regulations. The FDII provisions, added in the 2017 Tax Cuts . . .

Americas

China faces US, Hong Kong pressure to relax plan to tax worldwide income of individuals residing 183+ days there: Jane Cai / South China Morning Post→

November 5, 2018

Americas

US Democrats call TCJA international provisions a loophole-ridden “mess” that encourages overseas investment: US Senate Committee on Finance→

July 25, 2018

Apple pays Ireland 1.5 billion euros (USD 1.76 billion) in escrow toward 13 billion tax bill in State aid dispute: Reuters→

May 22, 2018

Americas

IRS clarifies withholding tax rules for dispositions of partnership interests by foreigners

April 2, 2018

The US IRS today issued new guidance on the withholding tax on dispositions by nonresident aliens or foreign corporations of partnership interests that . . .

Americas

UK says US-based MNEs underpaid GPB 4.6 billion (USD 5.9 billion) of UK tax last year: Out-law.com→

April 24, 2019

Americas

US issues technical corrections to final Section 965 regs on transition tax: Federal Register→

April 10, 2019

Americas

Draft US accounting standards update would require income tax disclosures to be disaggregated between federal, state, foreign: Financial Accounting Standards Board→

March 27, 2019

Americas

IRS announces extension of private letter ruling program for corporate stock distributions: Internal Revenue Service→

March 13, 2019

Americas

US FDII rules under review as potentially harmful tax regime, Treasury official says

February 19, 2019

The US’s foreign-derived intangibles income (FDII) tax rules are being scrutinized by the OECD’s Forum on Harmful Tax. . .

Americas

Outgoing US House GOP releases draft TCJA technical corrections: US Ways and Means→

January 2, 2019

Today, House Ways and Means Committee Chairman . . .

More: Discussion draft, JCT technical explanation.

Americas

Manal Corwin to lead KPMG’s Washington tax practice

November 14, 2018

Manal S. Corwin has been named principal-in-charge of KPMG’s . . .

Americas

China to immediately impose tariffs on 128 US products: Damian Paletta / The Washington Post→

April 2, 2018

Americas

US IRS releases frequently-asked-questions on new tax law’s deemed repatriation of foreign earnings

March 13, 2018

The US IRS today released frequently-asked-questions designed to help taxpayers meet the filing and payment obligations of the section 965 transition . . ,

Americas

Goodbye to All That?: A Requiem for the Destination-Based Cash Flow Tax: Daniel Shaviro / SSRN→

February 19, 2018

Americas

India, US sign agreement for exchange of country-by-country reports: Hindu Business Line→

March 27, 2019

Americas

France’s new digital tax could spur US countermeasures, lawmaker says: Kevin Brady / US House of Representatives→

March 6, 2019

Americas

US IRS proposes to withdraw controversial Section 385 debt-equity documentation regulations

September 23, 2018

The US IRS on September 21 proposed to revoke the hotly contested Section 385 debt-equity documentation regulations and work toward developing . . .

Americas

UK reverses support for EU interim digital tax fearing US retaliation, sources say: Bjarke Smith-Meyer / Politico→

April 29, 2018

Americas

IRS signed 116 advance pricing agreements in 2017

March 30, 2018

The US IRS today released statistics on the performance of its advance pricing agreement (APA) program in 2017, revealing that the tax agency signed 116 APAs that year. APA are agreements signed between the tax agency and multinational taxpayer resolving transfer pricing . .

Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

United States

US corps have repatriated fewer foreign profits than expected post-tax reform, blame foreign taxes: Laura Davison / Bloomberg→

December 7, 2018

The amount of offshore cash U.S. corporations have returned home so far this year . . .

More: ITEP, The Mercury News.

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Americas

US IRS to amend country-by-country reporting regulations to protect national security

March 30, 2018

The US IRS today announced that it will amend its guidance for large multinationals on country-by-country reporting obligations to prevent reporting that jeopardizes national . . .

Americas

US advance pricing agreement applications surged in 2018, data shows

March 27, 2019

The US IRS today issued its annual report providing statistics on its advance pricing agreement (APA) program. The data reveals a . . .

Americas

Facebook’s trial in $5 billion US transfer pricing dispute extended to Feb. 2020: Sony Kassam / Bloomberg Tax→

January 4, 2019

Americas

US Treasury Secretary Mnuchin decries “unilateral and unfair” digital tax proposals

October 25, 2018

US Treasury Secretary Steven Mnuchin today issued a statement condemning proposals being floated in the EU and elsewhere . . .

Americas

Despite US tax reform, companies still moving IP abroad: Laura Davison / Bloomberg→

October 16, 2018

Americas

US IRS again delays foreign currency tax regs

June 13, 2018

The US IRS today announced that it will further extend the due date of section 987 final and temporary regulations dealing with the taxation of foreign currency gains and losses. The regulations were originally published . . .

US can’t intervene in Apple’s European tax dispute, EU’s top court rules

May 21, 2018

The Court of Justice of the European Union (CJEU) has ruled that the United States may not intervene in the Apple state aid case, thus . . .

Americas

Morgan Lewis nabs three more Baker McKenzie tax pros

February 5, 2018

Morgan Lewis today announced the expansion of its Chicago tax team, adding three new partners: Joshua Richardson, Adam Beckerink, and Michael Liu. Richardson, Beckerink, and Liu are formerly with Baker McKenzie. They join Tom Linguanti . . .

Americas

Trump proposes 15 percent corporate tax rate, territorial tax system

April 26, 2017

President Trump on Wednesday unveiled his tax plan, proposing steep reductions in both individual and corporate income tax rates as well as a move to a territorial tax . . .

Americas

Saudi Arabia FATCA IGA signed with US

November 16, 2016

The US Treasury Department has today updated its FATCA website, reporting that Saudi Arabia has signed a Model 1 intergovernmental agreement (IGA) with . . .

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

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

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