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Companies face setback in challenge to District of Columbia’s use of Chainbridge transfer pricing method
Mark Nachbar and Mary Bernard of Ryan, LLC note the release of a surprising January 26 ruling in actions, brought by Hess, Exxon, and Shell, challenging the District of Columbia’s use of transfer pricing software developed by Chainbridge Software to assess millions in tax liabilities against them . . .
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US IRS issues final reporting, record keeping rules for foreign-owned disregarded domestic entities
The US IRS on December 13 published final tax regulations (T.D. 9796) under sections 6038A and 7701 that require wholly foreign-owned domestic disregarded entities to be treated as a domestic corporations, separate from their owners . . .
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Florida and Delaware LLPs and LLLPs to be taxed as corporations, Canadian tax officials say
Kabir Jamal, an attorney with Goodmans LLP, Toronto, discusses statements made by Canadian Revenue Agency officials at a conference last week announcing the agency’s decision to classify Florida and Delaware LLPs and LLLPs as corporations for income tax purposes . . .
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US disputes need for special digital economy tax rules, seeks consensus on profit allocation issues
The highly-anticipated interim report of the Task Force on the Digital Economy (TFDE), slated for release in April, will state that countries are divided on a long-term solution for taxing the digital economy, with the US arguing that there is no need for special tax rules in this area, said Chip Harter, Deputy Assistant Secretary (International Tax Affairs) at the US Department of the Treasury. Speaking in Washington at a Tax Council Policy Institute conference held . . .
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US Republican tax reform plan would rewrite international tax system
US House Republicans today presented their long-awaited tax reform bill, proposing to dramatically change the US international tax system.As expected, the Republican proposal includes a move to a territorial tax system accomplished by a foreign dividends received deduction. This is coupled with a deemed repatriation of existing earnings held offshore. The bill sets the deemed . . .
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US FATCA IGAs with Panama, Georgia enter into force; IGA with Antigua and Barbuda signed
The US Treasury Department today updated its FATCA website, reporting that Model 1 intergovernmental agreements (IGAs) entered . . .
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Mark Trivette joins Alvarez & Marsal Taxand’s Atlanta office
Mark Trivette has joined Alvarez & Marsal Taxand, Atlanta, as its new Managing Director . . .
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US Democrats introduce bill to close foreign reinsurance tax loophole
US Democrats on Wednesday introduced a bill designed to prevent foreign insurance groups from avoiding US tax by paying reinsurance premiums to affiliates located in tax . . .
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US criticizes EU probe of multinational corp tax as Apple decision nears
The Obama Administration, in a letter and white paper released today, ramped up its criticism of European Commission efforts to force large multinational firms to pay back amounts deemed illegal state aid that were allegedly received through overly generous tax rulings, known . . .
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Tax officials preview coming OECD guidance on profit splits, attribution of profits to PEs
Tax officials provided an update of international tax and transfer pricing guidance currently being developed at the OECD, including work on profit splits and on attribution of profits to permanent establishments (PEs), at Washington DC conference sponsored by the OECD, USCIB, and . . .
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US IRS issues regulations on partnership allocations of creditable foreign tax expenditures
The IRS on Wednesday released final, temporary, and proposed regulations applicable to partnerships that claim the foreign tax credit for foreign income taxes. The regulations. effective February 4, clarify aspects of the section 1.704-1(b)(4)(viii) safe harbor rule that allows allocations of. . .
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IRS signed fewer APAs in 2016, statistics show
The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
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