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US, Algeria FATCA agreement enters into force
The US Treasury Department has updated its FATCA website, reporting that a FATCA IGA signed by the US and Algeria entered . . .
Americas
Greece, US sign FATCA agreement
The US Treasury Department updated its FATCA website January 24, reporting that Greece has signed a Model 1 intergovernmental agreement (IGA) and an understanding . . .
Americas
New US House Ways and Means Committee members selected
US Reps. David Schweikert (R-AZ), Jackie Walorski (R-IN), Carlos Curbelo (R-FL), Brian Higgins (D-NY) . . .
Americas
US final, temporary tax regs on foreign currency gains and losses released
The US Treasury Department, on December 7, issued final, temporary, and proposed regulations relating to the taxation of foreign currency gains . . .
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MNEs with US activity vulnerable to US taxes on profits shifted to non-US group members using ECI theory, CPAs warn: Journal of Accountancy→
See: Profit Shifting: Effectively Connected Income and Financial Statement Risks, by Thomas J. Kelley, David L. Koontz, Jeffery M. Kadet. Available at: Journal of Accountancy.
Americas
US and India to begin negotiating bilateral APAs, 100 transfer pricing disputes resolved
Reassured by the successful settlement of numerous long-pending transfer pricing disputes, the US competent authority has agreed to soon begin negotiating bilateral advance . . .
Update (2/1/2016): US confirms it will accept Indian bilateral APA applications: The US IRS, on February 1, confirmed that, beginning February 16, the US competent authority will accept applications . . .
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Kautter formally nominated as US assistant secretary for Tax Policy
David J. Kautter has been nominated to serve as an US Assistant Secretary of the Treasury for Tax Policy, according. . .
Americas
Starbucks files suit challenging Commission’s decision on State aid in tax case
The European Court of Justice has today confirmed that Starbucks filed a suit in September challenging the European Commission’s decision of October 21, 2015, which concluded that an advance pricing agreement . . .
Americas
Macao and US sign Model 2 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Macao and the US have signed a Model 2 intergovernmental . . .
Americas
Final earnings stripping regulations released
The US Treasury Department on Thursday released final earnings stripping regulations under section 385, resisting calls by business and Republican lawmakers to slow down . . .
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Business reps urge overhaul of US debt/equity proposed regulations at hearing
Sam Olchyk and Arthur Norman of Venable LLP, Washington, report on a July 14 IRS hearing on controversial proposed section 385 earnings stripping regulations, noting that the speakers advanced a number of compelling arguments in favor of modifying the tax regulations, but IRS and Treasury officials remained mostly silent, not revealing their plans regarding the regulations . . .
Algeria
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US and Vietnam sign Model 1 FATCA IGA, agreement not treated as “in effect”
The US Treasury Department updated its FATCA website on April 19, reporting that Vietnam has signed a Model 1 intergovernmental agreement (IGA) with the. . .
Americas
US tax regulations extend foreign financial asset reporting to domestic entities
Michael J. Miller of Roberts & Holland, New York, reviews final US regulations, released February 23, that require domestic corporations, partnerships, and trusts to report their foreign financial assets to the IRS . . .
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Following Validus, US IRS concludes excise tax inapplicable to wholly foreign insurance transactions
The US IRS, in Rev. Rule 2016-3 issued on January 19, has announced that it will no longer apply the one-percent excise tax under section 4371(3) to premiums . . .
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