Africa
United States
Americas
Americas
Americas
Americas
Ireland, US multinationals to face new tax landscape in 2018
Jim Stewart, Trinity Business School, Trinity College, Dublin discusses how EU tax authorities’ increasing challenges to the tax strategies of US multinationals, their access to information about MNE activities, US tax reform, and the net effect of ‘correlative adjustments,’ are creating a new tax environment for US MNEs, Ireland, and international taxation in general . . .
Americas
Americas
Americas
Americas
Ukraine, US sign Model 1 FATCA agreement
Ukraine and the US have signed a Model 1 FATCA intergovernmental agreement (IGA) according to an . . .
Americas
Italy issues more tax guidance on controlled foreign companies
Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses guidance issued by the Italian tax authority on September 16 that provides important details on how to determine if Italy’s controlled foreign company (CFC) tax rules will apply . . .
Americas
Americas
Europe
Apple, Google, Fiat, IKEA, McDonald’s reps to be grilled on tax avoidance by EU Parliament committee
Representatives of large multinationals will again defend their companies’ tax avoidance practices before an EU parliamentary committee. This time, Apple, Google, Fiat, IKEA. . .
Americas
Americas
US IRS releases guidance on foreign tax refunds received by RICs
The US IRS on January 11 released Notice 2016-10, describing regulations Treasury intends to release relating to the treatment under sections 853 and 905(c) of foreign tax refunds . . .
Americas
US Senators urge Treasury to consider retaliatory EU tax in response to State aid cases
Four influential US Senators have urged the Obama administration to examine whether it should use its regulatory authority to impose additional taxes on EU citizens and corporations in retaliation for EU State aid . . .
Americas
Americas
Americas
Stanford fellow examines US tax and non-tax effects of corporate inversions: Cathy Hwang / SSRN →
The New Corporate Migration: Tax Diversion Through Inversion, by Cathy Hwang. See: SSRN.
Americas
Americas
Americas
Amanda Varma promoted to tax partner at Steptoe
Steptoe & Johnson, on January 4, announced that tax attorney Amanda Varma has been been promoted to . . .
Africa
US IRS adds foreign base company income issue to private ruling “no rule” list, updates private letter ruling procedures
The US IRS has released its annual “no rule” list, adding foreign base company income issues to the list of topics that the agency will “not ordinarily” address in private letter rulings . . .
Americas
US weighing changes to draft model tax treaty provisions, negotiating new treaty with Luxembourg
The US is considering changes to draft US Model Income Tax Convention provisions released last May, including several changes to provisions that deny tax treaty benefits to related party payments that are subject to a special tax regime (STR) . . .
Americas
US releases proposed regulations requiring country-by-country reporting by MNEs
The US IRS on December 21 released proposed regulations requiring annual country-by-country reporting . . .
FATCA/CRS
US posts two new FATCA FAQs
The US has posted new frequently asked questions (FAQs) to its FATCA website regarding registration for nonreporting financial institutions in Model 1 IGA jurisdictions and self-certifications on similarly agreed forms . . .
Americas
US IRS requests comments on compliance burdens associated with stock options under transfer pricing regs
The US IRS, on August 7, has requested public comments on the information collection requirements related to compensatory stock options under section 482 transfer pricing regulations . . .
Americas
US lawmakers to hold hearings on BEPS, EU State aid cases
(Updated 11/25/2015) The US Senate Finance Committee will consider the OECD/G20 base erosion profit shifting (BEPS) project and the European Commission’s State aid challenges to private tax rulings entered into between EU States . . .
Americas
Americas
Too big to tax? Vanguard and the arm’s length standard – Reuven S. Avi-Yonah / SSRN
Professor Reuven S. Avi-Yonah of Michigan Law School argues that the US IRS could launch a successful transfer pricing challenge to the fee arrangement between Vanguard’s investment manager company and its related mutual fund companies. See: SSRN.
Americas
Americas
US and Philippines sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that the Philippines has signed a Model 1 intergovernmental agreement (IGA) with the United States as of July 13. . .
Americas
Wyden bill would modify US PFIC rules for offshore reinsurance – PwC
A bill introduced by Senate Finance Committee Member Ron Wyden (D-Ore) to amend US passive foreign investment company (PFIC) rules would clarify the active insurance exception but could also create problems for companies that underwrite catastrophic risks, writes PwC in a June 29 analysis of the bill. See, PwC.
Americas
US and Croatia sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Croatia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of March 20. The text of the agreement is available. See: Model 1 IGA
Americas
US IRS updates FATCA IDES user guide, releases ICMM report notifications guides
The US IRS, on March 5, announced it has updated the FATCA international data exchange service (IDES) user guide to add user . . .
Americas
Carbone joins Willkie Farr & Gallagher in New York
Anthony J. Carbone has joined Willkie Farr & Gallagher’s New York office as a partner, the firm announced January 20. Formerly co-leader of Bingham McCutchen’s tax group, Carbone focuses on US and international tax planning strategies and the tax consequences of business and investment transactions. See, release.
Americas
Americas
US signs first competent authority arrangements to implement FATCA IGAs with Australia and UK
The US IRS announced November 24 that it has signed competent authority arrangements (CCAs) with Australia and the UK to establish . . .
Americas
US IRS’s Heather Maloy to join EY
EY has announced that Heather Maloy, the IRS Commissioner for the Large Business & International (LB&I) Division, will join the firm’s national tax department as tax controversy . . .
