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US planning international tax guidance on BEAT, GILTI, transition tax, Treasury official says
The US intends to issue proposed tax regulations next month addressing the section 965 transition tax followed by year-end guidance on the GILTI, BEAT, and other international tax provisions introduced in the 2017 Tax Cuts and Jobs Act, said Lafayette (Chip) G. Harter, Deputy Assistant Secretary (International Tax Affairs) at US Treasury during the 2018 OECD International Tax Conference, held . . .
Africa
Asia-Pacific
Europe
Asia-Pacific
Africa
Asia-Pacific
Asia-Pacific
Asia-Pacific
American Samoa
Europe
Denmark
Europe
Asia-Pacific
Europe
Europe
EU Commission investigating UK controlled foreign corporation law for State aid violation
The European Commission has opened an in-depth State aid investigation into the UK’s controlled foreign company (CFC) tax laws applicable to multinationals, specifically, the CFC rules’ group financing exception. The group financing exception to the CFC rules, added in 2013, is applicable to multinationals . . .
Asia-Pacific
Europe
EU court clarifies VAT treatment of personal contract purchases and other leases
The Court of Justice of the European Union’s much anticipated judgement in the Mercedes-Benz Financial Services UK Ltd case (Case C-164/16) was delivered on October 4, providing greater clarity on the VAT treatment of personal contract purchase agreements offered by car manufacturers and other companies, as well as on leases in general, writes UK tax specialist, Neil MacKay . . .
Americas
Digital Economy
ASEAN
Americas
Asia-Pacific
Europe
Europe
Asia-Pacific
Australia: related party financing faces heightened tax scrutiny
Zara Ritchie and Natalya Marenina of BDO discuss the implications of May 16 Australian Taxation Office (ATO) guidance setting out the ATO’s risk assessment framework for cross-border related party financing . . .
Europe
EU States must permit court challenge to tax information exchange request order, CJEU rules
EU states must allow a court challenge to the legality of an information order issued to implement a tax-related exchange of information request on the grounds that the request lacks “foreseeable relevance,” the Court of Justice. . .
Council of the EU
EU “tax certainty” effort won’t slow tax avoidance work, ECOFIN president assures
Enhancing EU tax certainty for multinational groups has become a hot topic. The subject was taken up during a recent informal meeting of the Economic and Financial Affairs Council (ECOFIN) in Malta and is also the focus of a new European Commission taxation paper . . .
Africa
Asia-Pacific
Americas
Mindy Herzfeld Joins Ivins Phillips & Barker
Mindy Herzfeld has joined Ivins, Phillips & Barker’s corporate and international tax groups located in Washington DC, the firm . . .
Europe
Irish government asks for public feedback on corporate tax code
The Irish government on February 21 launched a consultation seeking public feedback in connection with a review of Ireland’s corporation tax . . .
Europe
EU Parliament proposal would extend public country-by-country reporting to more multinationals
An EU Commission proposal to require public country-by-country reporting by multinationals operating in Europe should be extended to cover many more multinationals and to mandate much more robust . . .
Europe
Americas
US tax regs require gain recognition on transfer to partnership with related foreign partners
The US IRS on January 19 issued temporary (TD 9811) and proposed (REG-127203-15) regulations that require US persons to recognize gain on the transfer of appreciated property in exchange for an interest in partnership which has foreign partners . . .
Americas
