The US has released the text of an agreement signed by competent authorities of the US and Kazakhstan which concerns the eligibility of entities that are treated as fiscally transparent under a double tax agreement signed by the countries
. . .
Rep. Charles Boustany (R-La.) will head of the tax policy subcommittee of the Ways and Means Committee of the US House of Representatives . . .
The British Virgin Islands International Tax Authority on March 20 released guidance notes designed to provide practical assistance entities and their directors, officers, and advisers in complying with obligations under FATCA. See, FATCA Guidance, Version 2.0
US Senator Marco Rubio (R., Fla.), a likely 2016 Republican presidential candidate, and Senator Mike Lee (R., Utah) on March 4 released a tax plan that includes a proposal to adopt a territorial tax system. The Rubio-Lee plan would also . . .
Diana L. Wollman, former IRS director of international strategy in the Large Business and International Division, will join Cleary Gottlieb’s tax practice in New York as a partner where she will focus on tax controversy . . .
The Isle of Man on December 15 published revised Guidance Notes relating to intergovernmental agreements to improve international tax compliance signed in 2013 with the UK and US. Release.
The US IRS on October 27 released new questions and answers on the FATCA International Data Exchange Services (IDES) system on its website and listed approved certificate authorities.
The new Q&As are as . . .
The US Treasury Department has updated its FATCA website, reporting that Brazil has signed a Model 1 intergovernmental agreement (IGA) with the United States as of Sept. 23. Agreement
The European Court of Justice, in Kronos International Inc. released Sept 11, has ruled that a US registered company resident in Germany may assert that German tax rules violate free movement of capital, but the company may not claim freedom of establishment rights. The ECJ went on to reject the company’s contention that Germany’s tax rules in effect at the time, which permitted a set off for . . .
Hein & Associates LLP, on August 12, announced that Stephen T. Williams will be joining the firm’s Denver office as National Director of International Tax Services. Williams is formerly with PwC, Calgary. Release
For a WSJ interview of House Ways and Means Chairman Kevin Brady, see: The Wall Street Journal.
The US Treasury Department has updated its FATCA website, reporting that Montserrat has signed a Model 1 intergovernmental . . .
US Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Chairman Paul Ryan (R-WI) today sent a letter to Treasury Secretary Jack Lew asking Treasury stop work on a regulation project to . . .
The US IRS on April 20 announced it has updated the FATCA International Data Exchange Service (IDES) user guide to include enhancements for reporting. . .
The US Treasury Department has updated its FATCA website, reporting that Qatar has signed a Model 1 intergovernmental agreement (IGA) with the United States as of January 7. The text of the agreement is available. See, agreement.
EY announced November 19 that Ray Beeman, former adviser to Chairman of the House Ways and Means Committee Dave Camp, has joined Ernst & Young’s National Tax Department in Washington, DC. As Tax Counsel and Special Adviser for Tax Reform, Beeman developed discussion drafts related to international tax, financial products, and pass-throughs. He also helped prepare The Tax Reform Act of 2014, released by Chairman Camp in February. See, EY release.
A new FAQ was posted on the US IRS’s FATCA website on October 27 in the Branch/Disregarded Entity category. The FAQ . . .
The Obama administration will decide “in the very near future” whether it should exercise its regulatory authority to make corporate inversions less economically attractive, US Treasury Secretary Jacob Lew said on Sept. 8.
Speaking at the Urban Institute in Washington, Lew said that . . .
US Treasury Department has updated its FATCA website, reporting that Latvia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 27. Agreement
The US IRS today released to the public two more international practice . . .
Masao Yoshimura, an Associate Professor of Tax Law at Hitotsubashi University’s Graduate School of International Corporate Strategy, analyzes a July 17 decision of the Supreme Court of Japan concluding that Delaware limited partnerships should be classified as corporations for tax purposes . . .
Irish Revenue on June 17 released guidance on the treatment of holding companies and treasury companies for purposes of FATCA reporting, in light of updated US IRS guidance . . .
Of the 201 CEOs that make up the membership of the Business Roundtable, 111 lead US companies that use offshore tax havens, and many lead companies that pay little or no corporate tax despite being profitable, according to a report by ranking member of the US Senate Budget Committee, Bernie Sanders (I-Vt.), released . . .
The US IRS on December 11 added new information on its website on the FATCA International Data Exchange Service (IDES). The IRS describes the IDES enrollment process, lists compatible web browsers . . .
Pascal Saint-Amans, the director of the OECD Centre for Tax Policy and Administration, addressed Ireland’s recent tax announcements and his views on whether the US will implement or block the OECD/G-20 base erosion profit shifting measures during an interview with the Irish Independent. See, Irish Independent.
Countries negotiating the OECD/G-20 base erosion profit shifting (BEPS) guidance have advanced a proposal to require countries that seek access to country-by-country reporting data to first to agree to enhanced dispute resolution, a US Treasury official said on Sept 17.
Speaking during a Deloitte webinar, Robert Stack, US Treasury Deputy . . .
Sutherland Asbill & Brennan LLP has provided a report of a July 28 meeting of the Multistate Tax Commission’s Arm’s Length Adjustment Services Advisory Group, which is creating a transfer pricing model for the U.S. states and is considering ways to improve the states’ ability to analyze intercompany transactions. See, Sutherland SALT report.
The United States Council for International Business has written to US Treasury, arguing that draft provisions in the US model tax treaty released last May “tilt too far in their attempt to prevent inappropriate claims of treaty benefits.” The group is concerned with provisions on special regimes, subsequent changes in law, and limitation on benefits. See: USCIB. Related: MNE Tax.
The US IRS on September 2 released temporary and proposed regulations on the application of the section 956 deemed dividend rules to partnership transactions. Regs were also issued providing that a controlled foreign corporation (CFC) must conduct relevant activities itself to take advantage of the foreign personal holding company income (FPHCI) active rent and royalties exception, including in situations where a cost sharing . . .
The US IRS on August 27 released proposed amendments to regulations that would make more flexible the tests for determining whether an individual is a resident of a US territory . . .
Thomas H. Young has joined McDermott Will & Emery’s US and international tax practice group as a partner based in Chicago, the firm has announced. Young is formerly a senior manager of international tax at KPMG LLP, where . . .
The US Treasury Department has updated its FATCA website, reporting that Curacao has signed a Model 1 intergovernmental agreement (IGA) with the United States as of December 16, 2014. The text of the agreement is available. See, agreement.
Michael Lebovitz and Stephen Weerts have joined White & Case’s Los Angeles office, the firm announced January 5. The lawyers, both formerly with DLA Piper, will work on legal and tax aspects of international joint ventures, cross-border mergers and acquisitions, and international corporate finance and capital markets transactions. See, White & Case release.
The US IRS on October 10 released an advance copy of Notice 2014-59, expanding transition relief provided in Notice 2014-33 to withholding agents, foreign financial institutions, and payors that have withholding or information reporting requirements respect to accounts and obligations they open or enter into before January 1, 2015. See, Notice 2014-59
Sutherland Asbill & Brennan LLP has provided a detailed account of an October 6 meeting of the US Multistate Tax Commission’s Arm’s Length Adjustment Services Advisory Group, where seven external economic firms provided advice on ways the MTC could assist states with their transfer pricing challenges. For detailed discussion, see Sutherland Asbill & Brennan.
Two Canadian-U.S. dual citizens, on August 11, filed suit in the Federal Court of Canada challenging the constitutionality of the intergovernmental agreement signed by the U.S. and Canada that implements FATCA.
The lawsuit, funded by the Alliance for the Defense of Canadian Sovereignty (ADCS), alleges that the intergovernmental agreement violates provisions of the Canadian Charter of Rights and Freedoms . . .
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