United States
US Sens. Sanders, Schatz introduce tax bill to end deferral of multinational profits, close loopholes
US Senators Bernie Sanders (I-Vt.) and Brian Schatz (D-Hawaii) today introduced a tax bill designed to curtail . . .
IRS announces issue-based campaign to increase tax compliance of large companies, international business
The US IRS has announced that it has selected 13 tax and transfer pricing topics that it will focus on in an issue-based campaign to increase the tax compliance of large and/or international businesses. In a January 31 announcement, the IRS’ Large Business and International division (LB&I) said it will . . .
Guyana and Dominican Republic sign Model 1 FATCA IGAa with US
The US Treasury Department has updated its FATCA website, reporting that Guyana and the Dominican Republic have signed Model 1 intergovernmental . . .
US-Curaçao Model 1 FATCA agreement enters into force
US Treasury on August 5 announced on its website that a Model 1 FATCA intergovernmental agreement (IGA) signed by the US and Curaçao entered. . .
IRS issues tax guidance on US source dividend equivalent payments
The US Internal Revenue Service has today published final and temporary (TD 9815) and proposed (REG-135122-16) tax regulations providing guidance to nonresident alien individuals and foreign corporations that hold financial products providing for payments. . .
FATCA agreement between US and Hong Kong enters into force
US Treasury has today announced on its website that a Model 2 FATCA intergovernmental agreement (IGA) signed by the US and Hong Kong entered . . .
US, Luxembourg agree to tax treaty changes to prevent double nontaxation
The US Treasury Department today announced that the US and Luxembourg, during negotiations for new protocol to their 2000 tax treaty, have agreed to provisions to address tax avoidance through triangular and exempt permanent . . .
US IRS issues final tax regulations on disregarded stock in inversions
The US IRS has published final and temporary (TD 9812) and proposed (REG-135734-14) tax regulations under section 7874 designed to fight tax avoidance associated with the inversion . . .
US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
New Zealand proposes rules to combat multinational tax avoidance through use of hybrid mismatches
The New Zealand government has today released for discussion proposed measures to prevent multinational corporations from avoiding tax through use of hybrid mismatch . . .