The US IRS today updated its “no rule” list of topics that the agency will not ordinarily address in private letter rulings or determination letters, taking two issues off the list that relate to distributions of stock of controlled corporations under . . .
A US Department of Justice lawsuit filed in Federal court on Wednesday reveals that the IRS believes that Facebook may have significantly undervalued a transfer of intellectual property . . .
The US IRS on March 31 released statistics on the performance of the IRS’s Advance Pricing Mutual Agreement Program (APMA), revealing that taxpayers submitted . . .
The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
Steven T. Mnuchin was sworn in to serve as US Secretary of the Treasury on February 13. In this capacity, Mnuchin will be the principal. . .
The US IRS in late December issued a slew of FATCA guidance, including updated agreements for foreign financial institutions and qualified intermediaries (QIs). Included in the release were . . .
See: BBC News. More: CBS News, Wall Street Journal, Seattle Times. Original Source: WTO.
Sam Olchyk and Kiley Boland, Venable LLP, Washington discuss the a US Senate Finance Committee hearing held October 3, where tax professors expressed discontent with the current US international tax system and agreed that American companies are treated unfairly in comparison to foreign companies operating in the US . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about difficulties applying the House GOP’s destination-based cash flow proposal to partners and partnerships . . . .
International tax lawyer Natan Leyva has joined Vinson & Elkin’s Washington, DC office, the firm announced today . . .
The US Treasury Department today updated its FATCA website, reporting that the Dominican Republic the US signed a Model 1 intergovernmental . . .
Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .
US IRS and Treasury officials joined tax practitioners and corporate tax executives today to discuss key international tax and transfer pricing developments at the 30th Annual Institute on Current Issues in International Taxation, cosponsored by George Washington University Law School and the Internal Revenue . . .
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