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 assessment.
The plan, which describes 277 tax guidance projects that the government intends to work on from July 2015 through June 2016, includes a new project to draft “regulations under §§6011 and 6038 relating to the country-by-country reporting of income, earnings, taxes paid, and certain economic activity for transfer pricing risk assessment.”
Danielle E. Rolfes, international tax counsel at US Treasury, told a tax conference last June that the government believes it has the authority under existing statutory provisions to write regulations implementing the OECD-developed rules. This view may not be shared by some in the US Congress, though. Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Chairman Paul Ryan (R-WI) co-authored a letter June 9 to Treasury Secretary Jack Lew that called into question Treasury’s authority.
The 2015–2016 priority guidance plan also includes a new project to write guidance under §704(b) on the allocation by partnerships of foreign income tax. Another new project involves drafting guidance under §§877A(g)(4) and 7701(a)(50)(A) regarding relinquishing US citizenship.
The goverment also released a fourth quarter update to the 2014–2015 priority guidance plan.
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