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US IRS allows early parent-surrogate filing for country-by-country reporting
The US IRS on January 19 issued guidance providing a procedure for the ultimate parent entity of a US MNE group to voluntarily file Form 8975 for early reporting periods. The filing is required effectuate . . .
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US-Cambodia FATCA IGA enters into force
The US Treasury today announced on its website a Model 1 FATCA intergovernmental agreement (IGA) signed the US-Cambodia entered into . . .
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Sanders joins Dems urging public country-by-country tax reporting for US multinationals
US Democratic presidential candidate Sen. Bernie Sanders (I-VT) and three Senate colleagues on June 8 urged the Obama administration to require public disclosure of country-by-country tax reports of large multinational . . .
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US planning international tax guidance on BEAT, GILTI, transition tax, Treasury official says
The US intends to issue proposed tax regulations next month addressing the section 965 transition tax followed by year-end guidance on the GILTI, BEAT, and other international tax provisions introduced in the 2017 Tax Cuts and Jobs Act, said Lafayette (Chip) G. Harter, Deputy Assistant Secretary (International Tax Affairs) at US Treasury during the 2018 OECD International Tax Conference, held . . .
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Mindy Herzfeld Joins Ivins Phillips & Barker
Mindy Herzfeld has joined Ivins, Phillips & Barker’s corporate and international tax groups located in Washington DC, the firm . . .
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US tax regs require gain recognition on transfer to partnership with related foreign partners
The US IRS on January 19 issued temporary (TD 9811) and proposed (REG-127203-15) regulations that require US persons to recognize gain on the transfer of appreciated property in exchange for an interest in partnership which has foreign partners . . .
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US IRS to modify tax regs on triangular reorganizations involving foreign corporations; inbound nonrecognition transactions
The US IRS today announced that it will modify tax regulations under section 367 to address triangular reorganizations involving foreign corporations . . .
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US targets tax planning in advance of EU state aid, other foreign-initiated tax adjustments
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss newly issued Notice 2016-52, targeting tax planning undertaken by US multinationals that anticipate large foreign-initiated tax adjustments, noting that the guidance is not limited to adjustments under EU state aid law . . .
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Hank Gutman joins Ivins, Phillips & Barker
Former Chief of Staff of the Joint Committee on Taxation, Hank Gutman, has joined Ivins, Phillips & Barker, Washington, where he will lead firm’s federal tax policy . . .
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US threatens to stop treating some FATCA IGAs as being “in effect” in 2017
Beginning in 2017, the US will stop treating a country as if it has FATCA intergovernmental agreement (IGA) “in effect” if the country does not adequately prove that it has a plan . . .
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Countries targeted US companies in BEPS project to increase tax revenue, US Treasury official charges
Countries participating in the OECD/G20 base erosion profit shifting (BEPS) project sought to rewrite international tax rules for the digital economy and for intellectual property to increase their tax take at the expense of the United States, Robert Stack, Treasury deputy assistant secretary. . .
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US lawmakers stake out position on border adjustment tax
Sam Olchyk and Arthur Norman of Venable LLP, Washington. discuss a May 24 US House Ways and Means Committee hearing on tax reform where lawmakers addressed the border adjustment tax, business deductions, and passthroughs . . .
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US IRS releases updated foreign partnership, trust withholding agreements
The US IRS on January 20 released an updated withholding foreign partnership agreement (WP agreement) and withholding foreign trust agreement (WT agreement). The agreements, in . . .
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Mark Mazur named director of Tax Policy Center
Mark Mazur, Assistant Secretary for Tax Policy at the Department of the US Treasury, has been appointed as director of the Tax Policy . . . .
Americas
EU proposal to halt multinational tax avoidance through third-country hybrid mismatches stalls
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
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India, US resolve 108 more cross-border tax disputes, agree to first bilateral APA
India and US tax officials have resolved 108 mutual agreement procedure (MAP) tax disputes and have reached agreement on the their first bilateral advance pricing agreement (APA), India’s Central Board of Direct . . .
Americas
FATCA IGA between US and South Korea enters into force
The US Treasury Department has updated its FATCA website, reporting that a Model 1 intergovernmental agreement (IGA) signed by the US and South Korea . . .
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US IRS issues final country-by-country reporting regulations, rules permitting voluntary filing forthcoming
The US IRS today issued final regulations requiring large US parented mulitnational corporations to file annual country-by-country (CbC) reports consistent with OECD/G20 base erosion profit shifting (BEPS) project guidance, though taxpayers that wish to file voluntary reports for the 2016 tax year with the IRS will . . .
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