United States–MNE Tax

Americas

US business groups file lawsuit challenging tax inversion regulations

August 4, 2016

Two US business groups today filed a lawsuit in Federal court challenging the validity of US tax regulations aimed at stopping “serial” corporate . . .

Americas

Clinton advocates exit tax on corporate inversions on campaign trail: Naomi Jagoda / The Hill→

March 9, 2016

See: The Hill.

Americas

US must finalize TCJA international tax regs by June 22 to make them fully retroactive to date of law passage: Siri Bulusu, Isabel Gottlieb, Sony Kassam / Bloomberg Tax→

March 25, 2019

McDonald’s Luxembourg tax rulings are not illegal state aid even though tax was avoided, Commission concludes

September 19, 2018

The EU Commission today announced that it has determined that tax rulings granted by Luxembourg to McDonald’s in 2009 did not provide illegal state aid to the fast food . . .

Americas

Michael Desmond nominated for IRS Chief Counsel role

March 2, 2018

Micheal J. Desmond will be nominated IRS Chief Counsel and US Treasury Assistant General Counsel, the White House announced today. Desmond has been a sole practitioner . . .

Americas

US could defy WTO if it loses EU challenge to FDII, professors say: Reuven S. Avi-Yonah & Martin G. Vallespinos→

February 8, 2018

Americas

US President signs tax reform into law, SEC follows up with reporting guidance

December 22, 2017

US President Donald Trump today signed the Tax Cuts and Jobs Act into law, which, among other things, slashes the corporate tax rate, and completely changes the US’s international tax system. Securities Exchange Commission staff also followed up today with new guidance on how reflect the impact of the new law in . . .

Americas

Tax professors, other experts, identify flaws in US House, Senate tax bills, including international provisions

December 13, 2017

Thirteen prominent US tax professors and other tax experts have co-authored an important paper that identifies technical flaws and adverse consequences of the US House and Senate tax reform bills provisions, including key international tax reform . . .

Americas

US Senate Finance Committee proposal lowers tax plan’s minimum tax on intangible offshore income to 10 percent for first 10 years: Alex Parker / Law360→

November 16, 2017

Americas

US IRS adds new paragraph to tax regs on transfers of property to foreign corporations

November 15, 2017

The US IRS on November 15 issued a correction to tax regulations (TD 9803) dealing with transfers of property to foreign corporations. These regulations, published . . .

Americas

Danielle Rolfes Joins KPMG’s Washington National Tax office

September 14, 2017

Danielle Rolfes has joined KPMG LLP, as a partner and will co-head the International Tax Group of the firm’s Washington National Tax . . .

Americas

US seeks to intervene in Apple appeal of EU State aid case, sources say: Diane Bartz / Reuters→

July 4, 2017

Americas

Paper analyzes effect of US MNE foreign cash, ‘trapped cash,’ permanently reinvested earnings: Stacie Kelley Laplante & Wayne L. Nesbitt / SSRN→

May 31, 2017

Americas

Trump’s tax regulation order: what (besides earnings stripping) could be on the chopping block?

April 24, 2017

Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses a Trump administration executive order, issued last Friday, mandating the review of tax regulations, noting that those hoping the order will lead to the repeal of US earnings stripping and/or inversion tax regulations may wind up disappointed . . . .

Americas

Disallowance of US loss from worthless Russian sovereign debt upheld on appeal, purchase lacked substance: Steptoe & Johnson→

March 15, 2017

See: Steptoe & Johnson.

Apple’s tricky argument regarding subs’ income source may not sway EU court, NYU prof says: Daniel Shaviro / Start Making Sense→

February 23, 2017

See: Start Making Sense.

Americas

Proposed debt/equity tax regs need revision, Democrat and Republican lawmakers say

June 29, 2016

In separate letters, US House Ways and Means Committee Republicans and Democrats have expressed concerns about proposed tax regulations issued last April that recharacterize some cross-border loans . . .

Americas

US APMA using “Functional Cost Diagnostic Model” in bilateral APAs and MAP to assess transfer pricing where two or more parties contribute to business: PWC→

February 28, 2019

Americas

Key takeaways from the proposed foreign tax credit regulations

December 19, 2018

Amanda Varma and Greg Kidder of Steptoe & Johnson LLP, Washington, analyze the proposed foreign tax credit regulations released on November 23 . . .

Americas

Five highlights from the IRS’s proposed GILTI regulations

October 1, 2018

Amanda Varma and Greg Kidder of Steptoe & Johnson LLP, Washington, discuss in detail US regulations issued September 13 addressing the new global intangible low-taxed income (GILTI) regime . . .

Americas

New OECD project aims to encourage proper use of tax treaty principal purpose test, official says

June 10, 2018

The OECD is working on a project designed to encourage tax administrations to act reasonably when interpreting and applying the principal purpose test, an official said at the 2018 OECD International Tax Conference, held . . .

Americas

US Federal court grants IRS motion to dismiss Facebook suit, says company has no right to IRS Appeals in transfer pricing challenge: Leslie Book / Procedurally Taxing→

May 16, 2018

Americas

US tax reform seeks return of IP to US: Sam Schechner / Wall Street Journal [paywall]→

February 1, 2018

Americas

Medtronic and IRS battling $1.4 billion transfer pricing case in US federal court: Joe Carlson / Star Tribune→

November 28, 2017

Americas

Economist Kirk Hesser to lead Cherry Bekaert’s US transfer pricing practice

October 12, 2017

Economist Kirk A. Hesser has joined Cherry Bekaert as US leader of the firm’s transfer pricing services group and managing director of its Atlanta practice. Hesser is formerly managing director of transfer pricing at BDO, where he worked for 7 years, and has also worked. . .

Americas

US Republicans propose territorial tax system, global minimum tax

September 27, 2017

US Republican leaders today unveiled an a framework for crafting US tax reform, which includes a cut in the corporate tax rate to 20 percent, a move to a territorial tax system, and a global minimum tax. The Unified Framework for Fixing Our Broken Tax Code, jointly . . .

Progress needed on international tax rules for digital companies, OECD’s Saint-Amans says

September 14, 2017

Countries will continue to advance unilateral measures to tax digital businesses unless there is some sign that international consensus can be reached on appropriately taxing these firms, an OECD official warned Wednesday. Speaking during . . .

Americas

US Supreme Court won’t review Santander Holdings foreign tax credit/economic substance case: Thomson Reuters Tax & Accounting→

June 27, 2017

Americas

Steven Mnuchin tapped as US Treasury Secretary

November 30, 2016

US news sources have reported that President-elect Donald Trump has selected Steven Mnuchin for the post of Treasury . . .

Americas

US-Israel FATCA agreement enters into force

October 25, 2016

The US Treasury has announced on its website that the US-Israel Model 1 FATCA intergovernmental agreement (IGA), signed by the countries on June 30, 2014, entered . . .

Americas

Donna McComber rejoins Baker & McKenzie

October 6, 2016

Transfer pricing economist Donna McComber has rejoined Baker & McKenzie Consulting LLC as a Director of Economics . . .

Americas

EU Commission publishes decision to open McDonald’s state aid case on tax ruling

June 7, 2016

The European Commission on June 7 published the non-confidential version of its decision to open a State aid investigation into whether a tax ruling granted by Luxembourg to McDonald’s may have granted . . .

Americas

France claims McDonald’s paid excessive royalties to related Luxembourg entity, owes €300 million more tax: Jacky Naegelen / Reuters→

April 20, 2016

See: Reuters. More: Forbes, Financial Times .

Americas

US IRS issues final regulations on section 965 repatriation tax

January 18, 2019

The US IRS on January 15 published final regulations under section 965, which provides for a one-time transition . . .

Americas

Mark Madrian joins Valentiam Group’s US West Coast transfer pricing practice

January 9, 2019

Valentiam Group, a recently formed US transfer pricing and valuation firm, today announced that . . .

Americas

Tax lawyer Robert J. Kovacev joins Norton Rose Fulbright

September 12, 2018

Robert J. Kovacev has joined Norton Rose Fulbright as a partner in its Washington, DC and San Francisco offices; the firm announced . . .

Americas

Tax reform’s BEAT hits US MNE’s Bermuda reinsurance affiliates driving M&A activity: Bethan Moorcraft / Insurance Business→

September 10, 2018

United States

Lobby groups attack and defend US treatment of reinsurance under BEAT: Ezequiel Minaya & Nina Trentmann / WSJ→

August 22, 2018

Americas

US IRS issues final tax regulations addressing inversions

July 13, 2018

The US IRS on the Department of the Treasury on July 12 issued final tax regulations addressing . . .

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

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