The US IRS on August 12 released guidance specifying new procedures to request assistance from the US competent authority under income tax treaties and to obtain an advance pricing agreement . . .
The IRS will not release an updated XML schema for FATCA reporting (Form 8966) for tax year 2015, the agency said August 10. In a new . . .
The US Treasury Department has updated its FATCA website, reporting that Iceland has signed a Model 1 intergovernmental agreement (IGA) with the US as of May 25 and that Romania has signed a Model 1 IGA with the US as of May 28. The text of the agreements are available. See, FATCA IGA with Romania, FATCA IGA with Iceland.
The UK on May 26 updated the schema and supporting documents for Foreign Account Tax Compliance Act (FATCA) software . . .
The US IRS on May 6 issued two revenue rulings that conclude that transactions amount to section 351 transactions followed by D reorganizations . . .
Former US House of Representatives Ways and Means Committee Chairman Dave Camp (R-MI) has joined PwC as a senior policy advisor in its Washington National Tax Services practice, the firm announced . . .
The US IRS released updates to its frequently asked questions (FAQs) on the FATCA IDES system dated January 5. Under the “general questions” heading, the . . .
The US Tax Court in Securitas Holdings Inc. v. Comm., released October 29, has ruled that payments made under a brother-sister captive insurance arrangement were deductible insurance premiums because . . .
The U.S. Joint Committee on Taxation released a report on July 21 entitled “Present Law And Background Related To Proposals To Reform The Taxation Of Income Of Multinational Enterprises.” The report was prepared in connection with a Senate Finance Committee public hearing scheduled for July 22 on the taxation of cross-border income. Report, Prior coverage
The US Treasury Department has updated its FATCA website, reporting that Azerbaijan and the US signed a Model 1 intergovernmental agreement . . .
The US Treasury Department has updated its FATCA website, reporting that Portugal has signed a Model 1 intergovernmental agreement (IGA) with the United States . . .
The US IRS on April 3 issued final, temporary, and proposed regulations relating to the allocation of the credit for increasing research activities to corporations and trades or businesses under common control. See, TD 9717, REG-133489-13.
US Senate Finance Committee Chairman Orrin Hatch (R-Utah) and Ranking Member Ron Wyden (D-Ore.) have requested stakeholder input on US tax reform, including international tax reform. The goal is to provide input for five bipartisan Finance Committee working groups that . . .
Hareesh Dhawale has been appointed director of the US IRS’s advance pricing and mutual agreement (APMA) program in the Large Business and International Division, the IRS has announced. Dhawale has served as acting director of APMA since June 2014. APMA oversees the IRS’s advance pricing . . .
A new frequently asked question (FAQ) was posted to FATCA website on February 2 in the in “General Compliance” category, as . . .
William Alexander will join Skadden, Arps, Slate, Meagher, & Flom’s Washington, DC office, the firm announced January 8. Alexander, who has been with the IRS Office of Chief Counsel since 1990 and served as IRS associate chief counsel (corporate) for the last 12 years, will join Skadden’s global tax group . . .
The US Department of the Treasury’s Financial Crimes and Enforcement Network (FinCEN), on July 30, released proposed rules that would require banks and other financial institutions to learn and verify the identity of the beneficial owners of their legal entity clients . . .
Even though international agreements have been reached on combating tax avoidance through the OECD/G20 base erosion profit shifting (BEPS) plan initiative, it does not necessarily follow that US multinational . . .
US presidential candidate Donald Trump’s tax plan, unveiled September 28, includes proposals for a 15 percent tax rate on all business income, limits on interest deductions and other unspecified business deductions, a deemed repatriation of all overseas profits of US multinationals at a 10 percent rate, and an end to deferral. See: Trump plan. More: TaxVox, Fortune, Slate, Bloomberg, The Guardian, CNN, New York Times, Politico, Wall Street Journal.
US Treasury on May 20 released for public comment draft proposals that would significantly modify the US Model Income Tax Convention. Included are proposals to address stateless income, discourage corporate inversions, and permit expanded use of the treaty through a derivatives benefits rule. The next US model would also include a provision requiring dispute resolution . . .
The magnitude of profit shifting by American companies “may be significant,” a US Congressional Research Service (CRS) report has concluded. The report, released April 30, found that about 50 percent of the $1.2 trillion in overseas profit reported by American . . .
The Business Roundtable, an association of US company CEOs, on March 11 released a PWC report it commissioned which concludes that the US’s high tax rate coupled with its worldwide system of taxation disadvantages US businesses in the global cross-border mergers and acquisitions market, leading to foreign takeover of US businesses . . .
The Obama administration, in its FY 2016 Budget, has proposed a minimum tax on US multinational corporation foreign income and a one-time14 percent tax on previously untaxed foreign deferred profits. Inversion transactions and earnings stripping were also among the targets of the $4 trillion FY 2016 budget . . .
The US IRS on January 12 announced that its international data exchange service (IDES) website is open for enrollment. Financial institutions and host country tax authorities use IDES to electronically send information reports on financial accounts held by US persons to the IRS under the FATCA or pursuant. . .
International corporate tax lawyer Elan P. Keller has joined Kaye Scholer’s New York office as a partner, the firm announced January 5. Keller, a lawyer and a CPA, is formerly with Caplin & Drysdale and, prior to that, with Macquarie Holdings, Inc. See, release.
The US IRS on December 17 released a draft version of the FATCA International Data Exchange Services (IDES) user guide. The draft discusses data preparation procedures and reporting. A final version of the guide will be available January 2015. See, IDES user guide
Dallas-headquartered tax firm Ryan announced November 11 that it will acquire WTP Advisors, a Minneapolis-based international tax and transfer pricing firm. See, Ryan release.
In an October 24 letter, William J. Sample, Chair, Taxation Committee of the United States Council for International Business (USCIB) states that if adopted, the UN’s proposed modification to the commentary to Article 9 of the UN Model will lead to increased disputes and double taxation. Sample condemned the lack of input by stakeholders in the UN process and argues that is inappropriate for non-OECD countries that participated in OECD transfer pricing guideline negotiations and obtained concessions to “undercut” those negotiations by arguing elsewhere for positions that were rejected. USCIB
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The US Senate Finance Committee’s top Republican, on July 22, said that he would consider supporting legislation to stop corporate inversions, independent of comprehensive tax reform, as long conditions were met. . . .
US and Armenian officials will discuss the possibility of entering into negotiations to update their 1973 double tax treaty during the annual US-Armenia Economic Task Force meeting scheduled for . . .
The US IRS on April 23 issued proposed regulations (REG-108214-15) defining the terms “active conduct” and “insurance business” for purposes of determining when a foreign insurance company’s income is excluded from the definition of passive income under section 1297(b)(2)(B). The regulations . . .
UPDATE: See, also PWC.
The UK’s HM Revenue and Customs on October 13 launched an online FATCA guide to assist UK financial institutions in registering and reporting financial information on behalf of their US customers in accordance with UK-US legislation. HMRC
Kathryn Keneally will join DLA Piper’s global tax practice in October and will be based in the firm’s New York office. Keneally served as Assistant Attorney General for the Tax Division of the US Department of Justice from 2012–2014. Release
The U.S. IRS and Caterpillar, Inc., on July 31, filed a stipulated settlement, ending their U.S. Tax Court dispute over whether royalty income should be allocated to Caterpillar from the company’s Belgium and French subsidiaries. Tax Court Docket No. 010790-13, For analysis of the dispute, see post by Jerald David August of Fox Rothschild, LLP.
New frequently asked questions (FAQs) were posted to the US IRS’s FATCA website on March 24 concerning reporting deadlines and nil reporting. . .
Ireland’s Minister of Finance Micheal Noonan on March 11 signed an order to commence legislation that establishes the Irish collective asset-management vehicle (“ICAV”), a new Irish corporate vehicle for investment funds. The ICAV will be a corporate entity with . . .
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