United States–MNE Tax

Americas

US, Indonesia agree to exchange country-by-country data on multinationals to prevent tax avoidance

July 2, 2018

The US and Indonesia have signed a competent authority agreement providing for the exchange of country-by-country reporting data, US Treasury . . .

Americas

US imposes tariffs on EU, Canada, Mexico of 25 percent on imported steel, 10 percent on imported aluminum: Jeremy Diamond & Julia Horowitz / CNN Money→

May 31, 2018

Americas

New IRS rules aim to prevent avoidance of transition tax on foreign subsidiary earnings

April 2, 2018

The US IRS today published rules designed to prevent US companies from avoiding the new transition tax on untaxed foreign subsidiary earnings, added last December in the Tax Cuts and Jobs Act. The guidance, Notice 2018-26, also . . .

Americas

US, Cayman Islands negotiating exchange of country-by-country reports on large multinationals

February 27, 2018

The US and the Cayman Islands are negotiating competent authority agreement for the bilateral exchange of country-by-country reports on large multinationals, the US IRS announced . . .

Americas

US IRS to deny accounting period changes that avoid tax on deemed repatriation

February 13, 2018

The US IRS today announced it will deny a change in the accounting period of some US companies’ foreign affiliates if the change results in avoidance of the US’s newly enacted transition tax, which deems a repatriation of US company’s existing offshore earnings. Rev. Proc. 2018-17 prevents . . .

Americas

US Tax Cuts and Jobs Act provisions are not contrary to US treaty obligations: Reuven S. Avi-Yonah / SSRN→

January 23, 2018

Americas

US Republican tax reform proposal may punish companies that continue to sell in US after moving offshore: Brian Faler / Politico→

October 31, 2017

Americas

US, Bermuda negotiating exchange of country-by-country tax reports on multinational firms

September 7, 2017

The US is negotiating with Bermuda to annually exchange country-by-country reports on large multinational businesses, the IRS said today. The exchange relates to a 2015 deal reached between nations resulting . . .

Americas

Trump budget advocates territorial tax system, omits border adjustment

May 23, 2017

US President Trump today released his first budget, presenting tax proposals that echo the principles that the Administration . . .

Americas

Fight brewing over effort to roll back US debt/equity tax regulations

February 9, 2017

US Democrats on the House Ways and Means Committee today urged their colleagues to oppose an effort to repeal the final Section 385 debt/equity . . .

Americas

EU’s Vestager says Apple state aid decision may take awhile: Aoife White & Stephanie Bodoni / Bloomberg Business →

March 9, 2016

See: Bloomberg Business. More: Irish Examiner.

2016 US model tax treaty differs significantly from draft version, practitioners say

February 19, 2016

US Treasury has published an updated US model tax treaty, making significant revisions to the text of draft treaty provisions released last May. The 2016 US Model Income Tax Convention, published on Wednesday, will be . . .

Americas

TCJA “Blue Book” released: Joint Committee on Taxation→

December 20, 2018

Source: JCS-1-18

Americas

The Wayfair decision: what companies need to know about the new US sales tax landscape

July 25, 2018

Michael Bernard and Nancy Manzano of Vertex Inc. review the US states’ responses so far to last month’s US Supreme Court ruling in South Dakota v. Wayfair, which permits the states to levy sales tax on out-of-state merchants, and discuss how companies can prepare for the changed environment . . .

Americas

Vince Capurso is Warner Music Group’s new head of global tax

March 5, 2018

Vince Capurso has joined music recording company Warner Music Group as the firm’s new Global Head of Tax as of . . .

Americas

Altera case shows that US believes it is bound by arm’s length standard in non-treaty cases: Reuven S. Avi-Yonah / Michigan Journal of International Law→

November 20, 2017

Americas

Court approves US’s denial of tax benefits under US-Swiss treaty, principal purpose test considered: Starr International Company v. US→

August 16, 2017

Americas

US border tax will be WTO compliant, Brady says: Sahil Kapur and Lynnley Browning / Bloomberg→

February 15, 2017

See: Bloomberg.

Americas

US, Mexico agree to transfer pricing framework for maquiladoras

October 14, 2016

The US IRS today announced agreement with Mexico on a transfer pricing framework for US multinational enterprises that have maquiladora operations which, if applied in . . .

Americas

Israeli High Court concludes law implementing FATCA is valid: Dov Benovadia / Hamodia→

September 13, 2016

See: Hamodia.

US and EU officials to discuss State aid case against Apple: Stephanie Bodoni & Aoife White / Bloomberg →

July 12, 2016

See: Bloomberg.

Americas

US group urges Congress to cut OECD funding, claims US harmed by BEPS international tax standards

May 18, 2016

Representatives about 20 US advocacy groups, in a May 12 letter, urged Congress to stop funding the OECD, arguing that its work developing worldwide standards to tax multinational . . .

Americas

Prof. suggests US take IP under eminent domain at price IP transferred to tax haven: Andrew Blair-Stanek / SSRN→

April 22, 2016

See: SSRN.

Americas

US tax officials highlight key provisions in new BEAT regulations

December 17, 2018

US IRS and Treasury officials on December 14 discussed the just-released proposed base erosion anti-abuse tax (BEAT) regulations at a Washington DC tax conference, explaining the . . .

Americas

US proposed tax regs align “deemed dividend” rules with new international tax law

October 31, 2018

The US IRS and Treasury today issued proposed regulations aiming to remove inconsistencies between the section 956 “dividend equivalent” regulations and the new international tax . . .

Americas

US IRS announces changes to the CAP pre-filing program for large taxpayers: Internal Revenue Service→

August 28, 2018

Africa

US agrees to exchange country-by-country tax reports with Liechtenstein and Mauritius

May 16, 2018

US IRS has announced that it has agreed to exchange country-by-country reports on large multinationals with Liechtenstein and Mauritius.

The agreement . . .

Americas

US IRS updates Q&As on country-by-country reporting to reflect national security exception

April 11, 2018

The US IRS on April 10 added two new entries to its Q&As that provide guidance to large multinationals that must file country-by-country reports on their tax affairs with the government. Both entries address the new national security exception to country-by-country guidance, discussed . . .

Algeria

Former Microsoft tax counsel Mike Bernard joins Vertex

March 21, 2018

Vertex, a provider of tax technology solutions for corporations, has announced that Mike Bernard has joined the company as its new Chief Tax Officer. Bernard will . . .

Americas

Final US tax bill rewrites international tax system

December 17, 2017

International tax practitioners will need to quickly become familiar with an entirely new US international tax system and the acronyms that go with it — GILTI, FDII, BEAT — as Republican lawmakers on Friday reached . . .

Americas

US tax planning after the MLI: Jeffrey L. Rubinger & Summer Ayers LePree / Taxes Without Borders→

June 28, 2017

Americas

Trump’s address to Congress offers few details on tax reform: Steptoe & Johnson→

March 1, 2017

See: Steptoe & Johnson

Apple may lose EU State aid dispute, tax experts say

December 20, 2016

The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company’s subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .

Americas

US IRS adds two new international tax projects to priority guidance list

August 15, 2016

The US IRS on August 15 released its list of priority tax guidance projects for 2016-17, revealing that the agency has decided to work on issuing guidance in the areas of foreign currency contracts and country-by-country . . .

Americas

Apple could face $8 billion tax bill from EU State aid probe: Adam Satariano / Bloomberg Business→

January 19, 2016

See: Bloomberg Business. See also, The Guardian, Business Standard, Fortune, International Business Times, The Independent.

But see: Apple tax bill from EU State aid probe more likely about $200 million, not $8 billion: Tim Worstall / Forbes→

Americas

France’s digital tax may have discriminatory impact on US contrary to trade agreements, official says: Hamza Ali / Bloomberg Tax→

March 13, 2019

Africa

OECD releases updated report on “preferential tax regimes” benefiting multinationals

November 15, 2018

The OECD today released an updated report, approved by the 123-nation “Inclusive Framework on BEPS,” which identifies preferential tax . . .

Americas

Charles Schneider to lead Mazars USA tax practice

May 1, 2018

Mazars USA on May 1 announced that Charles Schneider has joined the firm as the National Tax Practice Leader. Schneider, a CPA, has spent most of his career advising large multinational . . .

Americas

New US guidance permits some MNEs to reduce tax on deemed repatriation: Lynnley Browning / Bloomberg→

April 4, 2018

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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