Americas
Philippines updates procedure for FATCA compliance
The Philippines Department of Finance on September 8 advised that since the FATCA intergovernmental agreement (IGA) between The Philippines and the US has not yet entered . . .
United States
Americas
US IRS releases agent training materials on transfer pricing, foreign-to-foreign transactions
The US IRS on August 28 released IRS agent training materials on transfer pricing rules under section 482 and on foreign-to-foreign transactions under . . .
Americas
G7 finance ministers agree on international tax priorities
G7 finance ministers and central bank governors agreed at a meeting in Dresden held May 27–29 that the mechanisms used to settle tax disputes between nations need to be improved, German Finance Minister Wolfgang Schaeuble said. Schaeuble told a press conference following . . .
Americas
Singapore updates FATCA reporting instructions
The Inland Revenue Authority of Singapore (IRAS) on April 17 updated information on its website concerning FATCA reporting. Changes were made to information on . . .
Europe
Switzerland and Liechtenstein reach agreement on double tax treaty
Switzerland and Liechtenstein have agreed to the terms of a revised double tax treaty and expect to sign the agreement this summer, Switzerland’s Federal Department of Finance (FDF) announced on February 5. The agreement, which would replace . . .
Americas
UK updates FATCA schema
The UK on January 13 released an updated schema and supporting documents for software developers working on the FATCA service . . .
Americas
US IRS updates tax forms and instructions for FATCA
The US IRS has posted new versions of forms and instructions to incorporate FATCA reporting requirements, as . . .
Americas
US to modify PFIC regulations to exempt some taxpayers that mark securities to market from reporting requirements
The US IRS, on Sept. 10, announced that it will amend reg. sec. 1.1298-1T of the passive foreign investment company (PFIC) regulations to provide that, generally, a US person that holds PFIC stock that is marked-to-market under a non-section 1296 mark-to-market regime, such as under section 475(f), will not be subject to the reporting . . .
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US tax bills would combat inversions by limiting excessive interest deductions, ending deferral
US lawmaker, Rep. Mark Pocan (D-WI), introduced two tax bills November 9 designed to take away tax benefits of corporate inversions . . .
Americas
Walter Nagel takes over as Gannett’s new tax chief
Walter Nagel has joined publisher Gannett as its vice president and chief tax officer, leaving . . .
Americas
Coca-Cola hit with $3.3 billion tax bill in transfer pricing dispute – Wall Street Journal
The company said the dispute is over income received from licensing its products to related parties located in foreign markets from 2007–2009. See: Wall Street Journal. More: Forbes, Business Insider, Market Watch.
Americas
US lawmakers release bipartisan ‘innovation box’ proposal to lower tax rate on IP income
US House Ways and Means Committee members Charles Boustany, Jr., (R-La.) and Richard Neal (D-Mass.) on July 29 released draft innovation box legislation that would lower the tax rate on income from intellectual property to about 10 percent, arguing that the proposal is needed to keep research . . .
Americas
US and UAE sign Model 1 FATCA IGA
The US Treasury Department updated its FATCA website reporting that the UAE has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 17. The text of the agreement is available. The countries, on June 10, 2014, agreed . . .
Americas
Kash Mansori joins WTP Advisors’ US transfer pricing practice
WTP Advisors announced February 4 that Kash Mansori, an economist and transfer pricing specialist, has joined the firm’s North Carolina office. Mansori previously had his own consulting practice, and has worked for Ernst & Young and Experis Finance. He was also an economics professor at Colby College where he conducted research on transfer pricing, international trade, and international finance.
Americas
US Senators urge IRS to tighten rules on inversions involving partnership structures
Five US senators have urged the IRS to take action to stop MNEs from establishing holding partnership structures to avoid paying taxes on recognized gain in an inversion, like the partnership structure used in the Burger King and Tim Hortons merger. . .
Americas
US IRS grants consent to change to elective method of measuring stock based compensation in CSA
The US IRS, in a private letter ruling released December 12, granted a corporation prospective consent to change to the elective method for measurement and timing of employee stock options, restricted shares, and restricted share units pursuant . . .
Americas
Americas
US IRS releases indirect foreign tax credit guidance
The US IRS on October 10 released Chief Counsel Advice 201441015, concluding that no portion of a controlled foreign corporation’s pre-1987 foreign income taxes are eligible to be deemed paid, including additional amounts paid in 2007 as a result of a redetermination of foreign tax. Chief Counsel Advice 201441015
Americas
US updates FATCA FAQs
New and updated FATCA frequently asked questions (FAQs) have been posted to the FATCA Website, as follows . . .
Americas
Former US IRS APMA program director joins Ernst & Young LLP
Ernst & Young LLP announced July 17 that Richard McAlonan, Jr. has joined the firm as director of national tax transfer pricing controversy in Washington, DC. McAlonan will also act as the Americas director of advance pricing agreements (APAs). McAlonan previously. . .
Americas
US likely lost USD 77–111 billion from MNE profit shifting in 2012, losing more now, says professor: SSRN→
See: The Effect of Profit Shifting on the Corporate Tax Base in the United States and Beyond, by Kimberly Clausing: SSRN
Americas
US should adopt territorial tax system and patent box, say bipartisan Senate working group chairmen
It is “imperative” that the US change its international tax system to a dividend exemption regime coupled with “robust and appropriate” base erosion rules, concluded the co-chairs of a US Senate bipartisan working group in a July 8 report. Senator Rob Portman (R-Ohio) and Senator Chuck Schumer (D-NY) said in the. . .
Americas
US IRS sticks with 25 percent bright line test for inversion regs’ substantial business activities test
Final US anti-inversion regulations published June 4 retain the 25 percent bright-line test of temporary and proposed versions of the regulations for determining if an expanded affiliated group (EAG) is considered to have substantial business activities in a foreign country. The regulations . . .
Americas
US Senate Finance Committee releases comments submitted to tax reform working groups
The US Senate Finance Committee on April 30 released comment letters submitted to Senate working groups that are currently analyzing US tax reform options. The comments were submitted in . . .
Americas
UK guidance implements automatic exchange of information
The UK government has released regulations implementing automatic exchange of information under the European Union Revised Directive on Administrative Cooperation and under the Multilateral Competent Authority Agreement implementing the Common Reporting Standard. The regulations, released March 24, also make minor changes to existing rules implementing the UK’s FATCA agreement . . .
Americas
Influential US senator calls for territorial tax system, says US should consider patent box
US Senator, Orrin Hatch, expected to be the next Chairman of the Senate Finance Committee, released a report December 11 which calls for the US to adopt a territorial tax system and suggests that the US consider adopting a patent or innovation box. The report . . .
Americas
India appealing High Court’s ruling in e-Funds
Indian tax authorities have lodged an appeal in the Supreme Court contesting the February 5 decision of the Delhi High Court in e-Funds IT Solutions/e-Funds Corp v. DIT, reports the Financial Express in a November 5 article. In e-Funds, the Delhi High Court concluded . . .
Americas
A. Duane Webber to head Baker and McKenzie’s global tax group
A. Duane Webber will chair Baker & McKenzie’s Global Tax group, the firm announced at its annual meeting held October 7. Webber is based in Washington, DC. Release.
Americas
Americas
Americas
US Tax Court again invalidates cost-sharing regs on stock-based compensation
In a significant blow to the IRS, the US Tax Court has invalidated 2003 cost-sharing regulations that require related parties to share stock-based compensation costs in qualified cost-sharing agreements, finding that the regulations do not meet the standard of reasoned . . .
Americas
Lawmakers embrace patent tax breaks – WSJ
Congressional tax writers are getting behind a major new tax break for profits made on patent portfolios as part of their ongoing quest to identify ways to make the U.S. tax code business-friendlier. Source: Lawmakers Embrace Patent Tax Breaks – WSJ
Americas
FATCA IDES user guide updated, testing session scheduled
The US IRS, on February 17, announced updates to the FATCA International Data Exchange Service (IDES) user guide, including a revised data preparation section and more instructions. The IRS also said that an IDES sample test file has been added to the IDES Data File Preparation page and has scheduled a FATCA IDES open testing session for financial institutions and tax . . .
Americas
Irish finance minister says German/UK patent box proposal may disadvantage small countries, worries BEPS will target US MNEs
Ireland may not support a proposal advanced by the UK and Germany to use a modified nexus approach to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting (BEPS) plan, Finance Minister Michael Noonan said December 2. The joint UK/German proposal, announced by the . . .
Americas
US IRS releases transfer pricing audit roadmap
The US IRS has released its Transfer Pricing Audit Roadmap, which provides recommended audit procedures, links to reference materials, and insight into what to expect during a transfer pricing examination. See, Roadmap, release. For analysis, see KPMG, PwC
Africa
OECD statistics show many unresolved MAP cases in Germany, US, Belgium, and France
Germany had the greatest number of unresolved mutual agreement procedure (MAP) cases among OECD countries during the 2014 reporting period, according to OECD statistics . . .
Americas
US releases international practice units
The US on October 29 released seven international practice units. . .
Americas
Canadian dual citizens move forward with FATCA IGA litigation – Tax, Society & Culture
Professor Allison Christians of McGill University provides an update of the lawsuit. See: Tax, Society & Culture. Related: MNE Tax.
Asia-Pacific
India changes procedures for registering and submitting forms under FATCA and CRS
The Indian government on September 4 updated the procedures that reporting financial institutions must follow to register and submit the Form 61B or nil statement for purposes of complying . . .
