The US Court of Appeals for the Fifth Circuit has ruled, in BMC Software Inc., decided March 13, that accounts receivables created under a transfer pricing closing agreement are not a related-party loans causing partial disallowance of the . . .
The US IRS on March 6 published proposed regulations (REG-100400-14) modifying rules that determine how to report a company’s items of income and deduction that occur on the day the company joins or leaves a consolidated group. The proposal would alter regulations . . .
The US IRS on February 27 published final regulations (TD 9712) on electing the alternative simplified credit under section 41(c)(5) of the Internal Revenue Code. Section 41(a) provides an incremental tax credit for increasing research activities based on a percentage of a taxpayer’s qualified research expenses . . .
The American Institute of CPAs (AICPA) announced on October 22 that it has appointed Troy K. Lewis chairman of its Tax Executive Committee. Lewis is vice president and chief enterprise risk management officer at Heritage Bank in St. George, Utah and is the sole proprietor of Lewis & Associates, CPAs, LLC based in Draper, Utah. Release
WTAS, a firm founded 12 years ago by members of now-defunct accounting firm Arthur Andersen, has renamed itself Andersen Tax. Andersen Tax will be a member of a newly created international entity called Andersen Global.
The firm has 17 offices in the US and locations in Switzerland, Russia, France, Italy, and The Netherlands. Release
The US IRS, on August 26, released its 2014–2015 priority guidance plan, which details the tax guidance it intends to work on from July 2014 through June 2015.
Notable international tax changes . . .
The U.S. IRS, on August 8, released Rev.Proc. 2014-47, which updates the Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) agreements for foreign partnerships and trusts that seek to enter into a WP or WT withholding agreement with the IRS under reg. section 1.1441-5(c)(2)(ii) and (e)(5)(iv). The new agreements replace agreements found in Rev. Proc. 2003-64, 2003-2 C.B. 306. Rev. Proc. 2014-47
US Treasury Department has updated its FATCA website, reporting that the Czech Republic has signed a Model 1 intergovernmental agreement (IGA) with the United States as of August 4. Agreement
See: Inversions and Competitiveness: Reflections in the Wake of Pfizer/Allergan by Reuven S. Avi-Yonh and Omri Y. Maria: SSRN.
“Any retroactive tax would be borne by US taxpayers in the form of a credit,” notes US deputy assistant secretary, Robert Stack. See: Financial Times
The US Treasury Department has updated its FATCA website, reporting that the Slovak Republic has signed a Model 1 intergovernmental agreement (IGA) with the US as . . .
The US IRS has released its annual “no rule” list, adding FATCA issues to the list of issues that the agency will “not ordinarily” address in private letter rulings or determination letters. . .
The U.S. IRS, on July 29, released an advance copy of Notice 2014-45, which expands on Notice 2014-44, released its July 21, concerning dispositions of assets following a section 901(m) covered asset . . .
The US IRS has issued final guidance under section 871(m) on dividend equivalent payments made to foreign corporations and nonresident aliens. The regulations, published in the Federal Register on September 18, establish . . .
The US is disappointed with much of the OECD/G20 base erosion profit shifting (BEPS) plan output, particularly work on permanent establishments (PEs), though it supports efforts on country-by-county reporting, dispute resolution, hybrids, and interest stripping, US Treasury officials said June 10–11 in Washington at the 2015 OECD International . . .
The US IRS signed significantly fewer advance pricing agreements (APAs) in 2014 as compared to the two previous years, according to statistics released by the goverment on March 30. A total of 101 APAs were signed in 2014, as compared to 145 in 2013 and 140 in. . .
The US Public Company Accounting Oversight Board is investigating whether PwC’s provision of both tax advice and auditing services to Caterpillar Inc. created a conflict of interest, and whether US rules should be modified to prohibit accounting firms from operating in these dual roles, according to a November 19 article by Michael Rapoport of the Wall Street Journal. For in-depth discussion, see Wall Street Journal.
The Rascon CPA Firm has provided a report of October 3 comments made by Robert Stack, Treasury deputy assistant secretary (International Tax Affairs) concerning the OECD’s base erosion . . .
Kirkland & Ellis LLP, on July 16, announced that Dean S. Shulman has joined the Firm’s New York office as a partner in the Tax Practice Group. Release
The US IRS, on June 24, released Rev. Proc. 2014-38, which includes a revised foreign financial institutions (FFI) agreement for FFIs that wish to enter into an agreement with the IRS to be treated as a participating FFI under the Foreign Account Tax Compliance Act (FATCA)
. . .
The US Treasury Department has updated its FATCA website, reporting that San Marino and the US signed a Model 2 intergovernmental . . .
The Indian government has announced that it has settled 35 transfer pricing disputes with the US in the information technology services and information technology enabled services industries thanks to a framework agreement signed . . .
The US IRS, in a technical advice memorandum released April 24, ruled that a refund claim filed in year 13 is not timely for taxes paid for year 2 if the claim for refund results from a net operating loss (NOL) in year 4 that was generated when the taxpayer made a timely election to deduct foreign taxes paid in lieu of the previously claimed . . .
The State of California Franchise Tax Board (FTB) has concluded that some payments received pursuant to a cost sharing arrangement (CSA) constitute gross receipts for purposes of the California sales factor. In TAM 2015-1, dated . . .
Wisconsin Republican, Paul Ryan, was named chair of the US congressional tax-writing panel, the House and Ways Committee, on November 19. Ryan will lead the Republicans’ efforts to reform the US tax code. See, Release – House Speaker John Boehner
Ryan, a global tax services firm, on June 3, announced that it has acquired Altus International, a Netherlands-based firm that provides transfer pricing, business restructuring, and valuation services. Release
The US IRS on December 7 published corrections to final and temporary regulations (TD 9734) issued September 18, changing the effective date . . .
The US IRS has announced that it will hold a hearing on September 18 on proposed regulations released April 23 that provide guidance . . .
The US Treasury’s 2015–2016 priority guidance plan, released July 31, reveals that the US government intends to develop regulations implementing OECD/G20 base erosion profit shifting (BEPS) plan rules requiring country-by-country reporting by multinational enterprises for transfer pricing risk. . .
The US IRS on December 30 announced, via a notice sent through its FATCA News and Information update service, that qualified intermediaries (QI), withholding foreign partnerships (WP), and withholding foreign trusts (WT) will be granted an extension of time to apply requirements of the joint account option under the QI agreement, WP agreement, or WT agreement. . .
The Obama administration on November 19 issued another package of tax measures designed to make it more difficult and less profitable for US companies to invert. The guidance, Notice 2015-79 supplements measures . . .
The US IRS has published proposed section 367 regulations that eliminate rules that allowed intangibles, including foreign goodwill and going concern value, to be transferred by a US person to a foreign corporation without gain recognition. The Service also released related . . .
The US and Vietnam signed a tax treaty on July 7, the US government has . . .
Walmart has stashed billions in 78 subsidiaries and branches located in 15 overseas tax havens, employing well-known international tax strategies to avoid paying foreign taxes in countries where it has retail operations and US taxes on foreign earnings, writes Americans for Tax Fairness in a . . .
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