Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses President Trump’s executive order mandating that for every new regulation issued, two must be removed, noting that it will be very difficult to apply this order to US tax regulations . . .
The US IRS today published final regulations (TD 9792) providing rules regarding US property held by a controlled foreign corporation (CFC) in connection with certain transactions . . .
The US IRS on January 19 announced in Notice 2016-08 that it will amend existing regulations under sections 1441–1464 and 1471–1474 regarding the timing of submitting preexisting . . .
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
The US IRS has released final regulations (TD 9803) under section 367 which eliminate the favorable tax treatment of outbound transfers . . .
Robert M. Gordon and Jennifer Crawford of True Partners Consulting LLC discuss the final US debt-equity regulations, focusing on the regs’ new documentation requirements for related party debt . . .
Medical device manufacturer Medtronic on June 9 won its transfer pricing dispute with the IRS in Tax Court, beating back the IRS’s claim that the medical device manufacturer should have reported increased US royalty payments and 2005 and 2006 from a related Puerto Rico . . .
The US and Switzerland have agreed that Swiss bank account owner identities can remain confidential for purposes of the Foreign Account Tax Compliance Act (FATCA) in some instances where the account is held . . .
The US Senate early Saturday morning passed its version of tax reform on a 51-49 vote. Like the House bill, passed in November, the Senate bill’s international tax provisions would dramatically alter the taxation of US and foreign-parented multinationals. In a late change, the Senate increased the tax rate on deemed repatriations of currently deferred . . . .
Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . .
Eli Miller will serve as US Treasury Chief of Staff, newly appointed US Secretary of the Treasury, Steven T. Mnuchin, announced . . .
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss final regulations released November 2 that clarify various issues arising under subpart F related concerning foreign partnerships and active rents and royalties . . .
The countries that have joined the inclusive framework established to carry out the work of the OECD/G20 base erosion profit shifting (BEPS) project are likely to eventually take on international tax work outside of the BEPS . . .
The US Treasury today announced a package of tax rules designed to discourage corporate inversions, including measures that restrict earnings stripping . . .
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