United States–MNE Tax

Accounting

FASB accounting standard update requires disclosure of government assistance

November 22, 2021

The US Financial Accounting Standards Board (FASB) on November 17 released an accounting standard update to require business entities to include information about certain types of government assistance that they receive in an annual disclosure in . . .

Americas

US corporate and global minimum tax measures clear House, debate moves to Senate

November 19, 2021

The US House of Representatives today approved a modified version of President Biden’s Build Back Better bill – including corporate and international tax changes – following protracted debates on the revenue and economic impacts of the provisions; the Senate will take up the bill sometime after . . .

Asia-Pacific

Australian Taxation Office’s transfer pricing audit of ResMed: an illustrative model

November 12, 2021

New York City Economist Dr. J. Harold McClure discusses medical equipment company ResMed’s settlement with the Australian Tax Office (ATO) for USD 381.7 million in additional taxes in connection with an ATO audit over certain transfer pricing issues between . . .

Americas

US corporate minimum tax proposal would likely hit several large companies in tech (Amazon, Google, Intel), telecom (Verizon, Comcast), banking (Morgan Stanley, JPMorgan Chase), and more: Kevin Schaul / Washington Post→

November 8, 2021

Accounting

Ireland considers new tax measures for outbound payments

November 5, 2021

The Irish Department of Finance on November 5 launched a public consultation on the introduction of new corporate tax rules applicable to outbound payments of interest, royalties, and dividends; the measures would deny . . .

Accounting

FASB accounting update addresses revenue contracts with acquired customers

November 5, 2021

The US Financial Accounting Standards Board (FASB) on October 28 released an accounting standard update with guidance on the accounting of revenue contracts with customers that are acquired in a business combination, which is intended to . . .

Americas

Global minimum tax will work, if implemented, OECD’s Saint-Amans says

November 4, 2021

OECD tax policy director Pascal Saint-Amans in a November 4 interview expressed that the political agreement on a 15% global minimum effective tax rate is a big deal, he is very pleased with the outcome, and he has little fear of companies attempting to exploit loopholes to evade the tax because . . .

Americas

Biden administration’s budget bill tax revenue estimates confirmed, partly

November 4, 2021

The revenue expected to be raised from the tax provisions included in the current draft of the Democrats’ Build Back Better budget is largely in line with the Biden administration’s claims, based on estimates released November 4 by the non-partisan US Congressional . . .

Accounting

US budget bill tax provisions’ effective dates, rates, thresholds

November 3, 2021

Following a November 2 off-year election that many pundits consider an initial bad omen for the Democrats, Biden and the party continue to finalize the details – and secure the votes – for the signature portion of the President’s agenda, including several notable corporate and international tax . . .

Accounting

American Institute of CPAs suggests Congress reconsider corporate minimum tax

November 2, 2021

The corporate minimum tax included in the budget reconciliation bill would create undue complexity and alter financial accounting decision making, according to an October 28 letter from the AICPA to lead congressional tax writers, saying this type of tax . . .

Americas

UK consults on introduction of corporate re-domiciliation regime

November 2, 2021

The UK government on October 27 opened a consultation on the possibility of introducing a “corporate re-domiciliation” regime to make it easier for companies to relocate to the UK while maintaining . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Americas

White House’s hopes of an international tax revenue windfall may be overblown

October 29, 2021

Alex M. Parker, Capitol Counsel LLC, discusses how, without the political support for raising tax rates, Democrats are looking to an overhaul of the international tax system to help pay for the USD 1.75 trillion spending package; but some recent estimates say . . .

Americas

Biden ‘confident’ has votes for new tax and spending framework

October 28, 2021

US President Biden announced on October 28 a new framework for his “Build Back Better” bill, which he is now “confident … can pass both houses of Congress,” following . . .

Accounting

US tax plan shifts, with corporate minimum tax in, rate hikes out

October 27, 2021

Democrats appear poised to adopt for their budget bill a corporate minimum tax of 15% on the book income of the most profitable companies, with an updated proposal for such a tax released October 26 by . . .

Accounting

FASB issues accounting standard update on private company stock compensation

October 26, 2021

The US Financial Accounting Standards Board (FASB) on October 25 published an accounting standard update (ASU) on determining the current price of an underlying share for equity-classified share-based awards by private companies, responding to . . .

Europe

Netherlands issues policy decree clarifying hybrid mismatch tax measures

October 25, 2021

Jian-Cheng Ku, Rhys Bane, and Mehdi el Manouzi, DLA Piper Nederland N.V., discuss the Dutch government’s October 11 decree clarifying hybrid mismatch measures of the EU Anti-Tax Avoidance Directive 2 (ATAD 2), based on the first experiences with the . . .

Americas

US corporate income tax receipts for fiscal year 2021 were above budget estimates by USD 103 billion (or about 38%) – with significantly higher receipts than expected attributed to ‘improved economy’: U.S. Department of Treasury→

October 22, 2021

Accounting

European digital services taxes to stay for now, with offsetting credits, countries agree

October 21, 2021

Under an October 21 agreement between the United States and Austria, France, Italy, Spain, and the UK, the European countries can keep their existing digital services taxes in place pending implementation of Pillar 1 of the OECD global tax deal; however, multinational groups . . .

Americas

US IRS outlines R&D tax credit claim information requirements

October 18, 2021

New guidance from the Internal Revenue Service specifies information that taxpayers must provide when filing research and development (R&D) tax credit claims for their claims to be . . .

Americas

US Democrats consider delaying until 2023 hike in global intangible low-taxed income (GILTI) rate, and possibly only increasing to 15%, to align with OECD agreement, appease moderates: Laura Weiss / Roll Call→

October 15, 2021

Accounting

US IRS again defers applicability of rules on foreign-currency branch income

October 12, 2021

On October 12, the US Internal Revenue Service announced that it would amend certain regulations on the taxable income of “qualified business units,” such as foreign branches, that operate in a foreign currency to delay their applicability for . . .

Multinational

Global tax pact’s ‘revolution’ builds on old concepts – long-standing apportionment rules between US states in case of Pillar 1 and century-old ‘single tax principle’ in case of Pillar 2: Reuven Avi-Yonah / LinkedIn→

October 12, 2021

Americas

OECD and Ireland strike tax deal as others in EU line up, developing countries shrug

October 7, 2021

Ireland announced October 7 that it is joining the OECD tax deal, cutting the holdouts down to just five nations out of the 140 in the Inclusive Framework that are scheduled to meet Friday, October 8, to . . .

Americas

Switzerland, Estonia, Ireland seek concessions in global tax deal

October 4, 2021

OECD Secretary-General Mathias Cormann told the Swiss Finance Minister that he personally does not see a consensus on a global minimum tax at a rate above 15%, attempting to allay Swiss concerns about the Inclusive Framework’s July statement referring to . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Accounting

US House budget bill would postpone R&D tax expensing change

September 29, 2021

The reconciliation bill that passed the House Budget Committee on September 25 includes an amendment to delay for four years the requirement for companies to amortize research and development (R&D) expenditures beginning in . . .

Americas

Yellen defends corporate tax rate hikes as modest by historical standards

September 28, 2021

The Biden Administration’s proposed increases in corporate taxes would leave corporate tax rates in the US lower than they were at any point between World War II and the 2017 Tax Cuts and Jobs Act, Treasury Secretary Janet Yellen told the National Association for Business Economics on September 28, noting that . . .

US Democrats’ hopes of overhauling TCJA’s foreign taxes stemmed by global pressure

September 27, 2021

Alex M. Parker, Capitol Counsel LLC, discusses why the most recent version of the Democrats’ plan for overhauling the US tax code – approved by the House Ways and Means committee on September 15 – suggests the party may be backing down on its promise to repeal a key part of the Tax Cuts and Jobs Act’s . . .

Accounting

Groups urge FASB to prioritize public country-by-country tax reporting

September 23, 2021

The US Financial Accounting Standards Board should adopt in its standard-setting agenda a requirement for companies to report information in the notes to their financial statements on the disaggregation of country-by-country income tax, according to a September 22 letter signed by 63 organizations that . . .

Accounting

US IRS finalizes rules on qualified business asset investment calculations, NOL carrybacks

September 22, 2021

On September 21, the IRS published final regulations on calculating qualified business asset investment (QBAI) under the global intangible-low taxed income (GILTI) and foreign-derived intangible income (FDII) provisions, along with . . .

Europe

American Chamber of Commerce in Ireland advises Irish Finance Minister that it’s not in country’s interests to resist a global minimum tax agreement: Arthur Beesley & Naomi O’Leary / Irish Times→

September 20, 2021

Accounting

FASB proposes accounting update on fair value for equity securities

September 17, 2021

The US Financial Accounting Standards Board (FASB) on September 15 outlined a proposal to clarify guidance on measuring the fair value of equity securities and to revise an example relating to contractual restrictions that prohibit the sale of an . . .

Africa

India proposes rules to implement farewell to the retro tax

September 16, 2021

Suranjali Tandon, National Institute of Public Finance and Policy, discusses India’s Central Board of Direct Taxes August 28 publication of a consultation document on proposed rules to remove the controversial retroactive application of a law taxing indirect transfers of assets situated in . . .

Americas

Asia to see disparate impacts from global digital tax reforms, IMF reports

September 15, 2021

Global tax reform efforts to address digitalization of the economy would likely have modest revenue effects in Asia, on the whole, according to a September 14 report from the International Monetary Fund; however, the effects would be uneven . . .

Americas

India-US bilateral advance pricing agreements and tax benefits for US multinationals

September 15, 2021

E. Miller Williams, Jr. and Richard L. Slowinski, Alston & Bird, discuss the growing demand for bilateral advance pricing agreements (APAs) between India and the US due to the high potential for adjustments and the risk of . . .

Americas

US House bill adds detail, moderation to corporate tax reform plans

September 13, 2021

Legislative corporate and international tax proposals to fund the Democrats’ budget reconciliation bill unveiled September 12 by House Ways and Means Committee Chairman Richard Neal (D-Mass.) contain the most comprehensive legislative language to date for . . .

Americas

US Senate bill would amend pass-through rules to address corporate tax abuse

September 10, 2021

Senate Finance Committee Senator Ron Wyden (D-Ore.) released a discussion draft on September 10 for legislation that would tighten rules around partnerships and other pass-through entities to prevent large corporations and wealthy investors from . . .

Accounting

US IRS priority plan adds tax projects on intangibles, hybrids, R&D

September 10, 2021

The US Internal Revenue Service priority guidance plan for 2021–2022, released September 9, lists several new corporate and international tax guidance projects for the coming year, supplementing . . .

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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