Afleveringen
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A review of the week's major US international tax-related news. In this edition:
President-elect Trump to usher in new administration on 20 January β US House passes Taiwan tax bill β US officials address CAMT guidance β US, France issue statement on exchange of CbC reports for 2024 and 2025 β US officials comment on BEPS 2.0 project β OECD IF co-chairs provide status report on Pillar One Amount A and B β OECD compiling list of related-party transactions used to thwart Pillar Two global minimum tax β OECD releases three packages of BEPS Pillar Two 2.0 global minimum tax guidance.
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A review of the week's major US international tax-related news. In this edition:
President-elect Trump open to two budget reconciliation bills, prefers one β House W&M Committee leaders introduce Taiwan tax bill β IRS issues comprehensive package on classification, sourcing of digital content and cloud transactions β IRS releases final regulations on DPLs, extending BEPS Pillar 2 transition relief for DCLs β Final rules released on certain partnership related-party basis shifting transactions β IRS CCA addresses transaction reducing future GILTI inclusion.
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Zijn er afleveringen die ontbreken?
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A review of the week's major US international tax-related news. In this edition:
US House and Senate return to Washington, House retains Johnson as Speaker β Congressional Republicans lack unanimity on path forward for budget reconciliation β IRS releases technical corrections to CAMT regulations β IRS issues final consolidated return regulations β Cryptocurrency guidance released β IRS will apply economic substance doctrine to transfer pricing cases β UN General Assembly approves resolution on terms for UN Framework Convention on International Tax Cooperation.
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A review of the week's major US international tax-related news. In this edition:
US Congressional Republicans continue to hold differing views on 2025 budget reconciliation β US to adopt OECD's Amount B simplified and streamlined approach to intercompany transactions beginning 2025 β US announces partial suspension of 1973 US-USSR tax treaty application to Belarus β US international tax officials leaving government β OECD BEPS project update β OECD releases pricing automation tool and fact sheets to implement BEPS Pillar One Amount B β OECD releases peer review report on Action 5 exchange of tax rulings.
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A review of the week's major US international tax-related news. In this edition:
US Congressional Republicans consider plans for budget reconciliation bills in 2025 β Congress must pass government funding by 20 December, US-Taiwan tax bill still possible β IRS issues final and proposed FX regulations β US-Norway CAA released β IRS requests comments on APA and mutual agreement procedures.
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A review of the week's major US international tax-related news. In this edition:
Congressional Republicans consider budget reconciliation options to enact legislative agenda β Congress to address government funding that expires on 20 December 2024 β President-elect Trump nominates new IRS Commissioner β IRS releases long-awaited PTEP proposed regulations β Cyprus clarifies exchange of CbC reports with US.
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A review of the week's major US international tax-related news. In this edition:
President-elect Trump nominates Treasury Secretary, fills out economic team G20 Leadersβ Declaration addresses international tax and BEPS 2.0 project OECD Global Forum on Transparency / Information Exchange announces 61 jurisdictions joining CARF -
A review of the week's major US international tax-related news. In this edition:
Republican US election sweep likely means TCJA extension via reconciliation, BEPS 2.0 project uncertainty β Final IRS Section 987 FX gain / loss regulations release before year-end β IRS comments on new passthrough field unit organization β IRS will permit digital asset transaction reporting on schema, not IRS Form 1042-S β IRS official says companies that ignored TP compliance letters referred for examination.
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A review of the week's major US international tax-related news. In this edition:
US announces tax agreement negotiations with Taiwan β IRS launches new LB&I pass-through field operations unit, EYβs Jeff Erickson chosen to lead β IRS announces new FATCA relief for FFIs β US officials discuss coming changes to CAMT regs β IRS official recommends expanding OECD Treaty Article 25 MAP scope β OECD official offers BEPS IF update.
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A review of the week's major US international tax-related news. In this edition:
US House legislators urge Taiwan tax negotiation β IRS launches new LB&I passthrough field operations unit β IRS official discusses CAMT campaign β OECD releases tax report to G20 Finance Ministers and Central Bank Governors.
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A review of the week's major US international tax-related news. In this edition:
Congress out of session until mid-November despite calls to reconvene and pass necessary funding measures β Upcoming election too close to predict for both presidential and congressional races β 2024 Annual Meetings of the IMF and World Bank Group to take place in Washington next week β IRS releases AM 2024-002 addressing application of Section 246(b) limitation to deductions under Sections 243, 245 and 250 β Italy and France propose changes to their digital services taxes, potentially increasing tax burdens on technology companies.
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A review of the week's major US international tax-related news. In this edition:
IRS releases final IP repatriation regulations β Treasury and IRS will release technical corrections to CAMT regs β IRS final DCL regulations will clarify anti-avoidance rule β OECD issues working paper on tax arbitrage through closely held businesses.
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A review of the week's major US international tax-related news. In this edition:
US general election will have major impact on tax policy IRS to update draft digital asset reporting instructions for Form 1099-DA OECD issues FAQs on CARF EY releases comprehensive analysis of proposed CAMT regs -
A review of this week's major US international tax-related news. In this edition:
US presidential candidates reveal tax positions β Congress averts government shutdown with continuing resolution, adjourns until after election β US officials discuss CAMT β Digital asset noncustodial broker reporting guidance coming before year end β Puerto Rico initiates public consultation on BEPS 2.0 GloBE rules β OECD holds signing ceremony for BEPS Pillar Two Subject to Tax Rule Multilateral Instrument.
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A review of this week's major US international tax-related news. In this edition:
US House Speaker promises βDay Oneβ focus on corporate tax policy with Republican election sweep β IRS soon to release final Section 367(d) regs on IP repatriation β IRS final Section 987 FX regs to reserve on partnership issues β IRS guidance on BEPS Pillar One Amount B coming before year end β IRS official clarifies βdisregarded payment lossβ rules effective date in recent DCL regs β IRS soon to release guidance on MAP and APA program β IRS assembling CAP transfer pricing team β OECD issues seventh annual BEPS Action 13 CbCR peer review report.
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A review of this week's major US international tax-related news. In this edition:
US Treasury issues proposed regulations on CAMT, extends penalty relief for failure to pay estimated CAMT β Treasury and IRS officials to evaluate narrowing scope of future anti-partnership basis-shifting guidance β Official offers international regulatory update β OECD releases standardized ICAP template for tax administration outcome letters β OECD to address incentives that undermine BEPS Pillar Two GloBE rules.
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A review of this week's major US international tax-related news. In this edition:
US Congress to return to Washington β IRS corrects proposed regs to permit foreign currency mark-to-market election to be made with returns filed after 19 August 2024 β USTR requests dispute settlement consultations with Canada under USMCA to address recent enactment of Canadian DST.
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A review of this week's major US international tax-related news. In this edition:
US Tax Court rules taxpayer entitled to DRD, but limits foreign tax credit.
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