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The South African Revenue Service on February 12 released draft guidance interpreting special tax incentives for headquarters companies, designed to encourage MNEs to locate operations in South Africa as a gateway to African investment. The law, effective for tax years after January 1, 2011, provides special tax breaks for qualifying. . .
Colombia’s president has signed into law a tax reform package which includes a temporary annual tax on wealth in excess of $1 billion pesos (USD 425,000) held by domestic or foreign legal entities, writes PwC in a December 28 tax alert. The tax package also includes increases in income tax withholding rates . . .
The International Consortium of Investigative Journalists (ICIJ) on December 9 published on the Internet 35 more leaked Luxembourg private tax rulings. The documents originated from the big four accounting firms, as well as from smaller Luxembourg-based tax firms and law . . .
A Russian proposal to tax controlled foreign corporations (CFCs) was passed by the Council of the Federation on November 19 and by the State Duma the day before, Russian news agency TASS and the Russian Legal Information Agency have reported. Known as the “deoffshorization” proposal. . .
The OECD on October 31 released a discussion draft on the artificial avoidance of permanent establishment ( PE) status, addressing commissionaire structures, the avoidance of PE status through specific activity exemptions, and other issues. The draft responds to Action 7 of the OECD/G-20 Action Plan on Base Erosion and Profit Shifting (BEPS), issued
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UPDATE: OECD to hold January 21 consultation on draft rules to stop avoidance of PE status: Requests to attend or speak are due January 9.
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
Poland’s President, Bronislaw Komorowski, on Sept. 17, signed into law changes to the thin capitalization rules that reduce the debt-to-equity ratio to 1:1, broaden the definition of “qualifying entity,” extend the rules to indirect relationships, and introduce new methods to determine tax deducible interest limits, writes KPMG Poland in an Oct. 2 report. For discussion of the new law, see KPMG (PDF 126 KB).
India’s Supreme Court has ruled that the law establishing India’s National Tax Tribunal (NTT) is unconstitutional, including a section of the law that allowed chartered accountants and corporate secretaries to represent parties before the NTT.
The decision concerns the 2005 NTT Act, which established specialized tribunals . . .
The OECD has announced that it will publish its first set of deliverables under the OECD/G20 Base Erosion and Profit Shifting (BEPS) action plan on Sept. 16, and that it will hold a technical conference on the release the same day, streamed live on the internet. . .
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
India’s Ministry of Finance, on June 25, announced that the government will extend excise duty concessions for cars and other vehicles until December 31. The concessions were originally
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The Australian Taxation Office has ruled, in a May 30 interpretative decision. . .
See: Inversions and Competitiveness: Reflections in the Wake of Pfizer/Allergan by Reuven S. Avi-Yonh and Omri Y. Maria: SSRN.
See: Royalties in Australia: Task Technology and Seven Network Cases by Richard J. Vann: 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
Switzerland’s Federal Council on September 11 proposed to extend the temporary withholding tax exemption for interest paid on contingent convertible bonds (CoCos) and write-off bonds of systematically important banks and to establish a similar . . .
The Guideline for Tax Risk Management of Fees paid to Overseas Related Parties, issued June 30, interprets Announcement 16, released in March, writes EY. See: EY
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 OECD on July 9 launched consultation on a draft paper offering guidance to low income countries on the use of tax incentives for investment. The consultation responds to a G20 Development Working Group’s. . .
A European Parliament committee has published letters from EU member state officials describing tax ruling practices, efforts to combat tax avoidance, and compliance with EU spontaneous exchange of information directives. The letters, published by. . .
Switzerland’s Federal Council announced June 24 that it will no longer pursue reforming the withholding tax system applicable to bond interest switching from the debtor principle to the paying agent . . .
India, Australia, Canada, on June 3 signed the OECD common reporting standard multilateral competent authority agreement, paving the way for automatic exchange of information by the countries’ tax administration, according to press releases issued by the countries’s governments. Costa Rica, Indonesia, and New Zealand . . .
Sami Tuominen has joined Bird & Bird as a partner to head of its Finnish tax group based in Helsinki, the firm announced June 1. Tuominen joins from local law firm, Borenius. Tuominen, an author of tax treatises and a regular . . .
The OECD on May 15 released a revised discussion draft under action 7 of the OECD/G20 base erosion profit shifting (BEPS) action plan concerning artificial avoidance of permanent establishment (PE) status. The draft, prepared by Working Party No. 1 (WP1) of the. . .
Taiwan’s Ministry of Finance has announced it will modify transfer pricing rules for business restructuring, the profit split method, and reporting for companies merged or dissolved, writes PwC in a March 19 report. Amendments also revise advance pricing agreement requirements and introduce reverse calculation of revenue using the profit standard of the same trade. See, PwC.
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