US: IRS releases directives on transfer pricing examinations
On 12 January 2018, the IRS Large Business and International (LB&I) division publicly released a set of five LB&I directives as guidance with respect for examinations of transfer pricing issues. Interim Instructions on Issuance of
See MoreUS: IRS updates information concerning country-by-country (CbC) reporting
On 18 January 2018, the IRS issued a release announcing updates and information regarding country-by-country (CbC) reporting requirements in the United States. Under the update list, IRS publishes new content on Country-by-Country (CbC) reporting
See MoreUS: Government signs joint statement on exchange of country-by-country tax reports with France
On January 12, the IRS announced on its website that the US and French competent authorities would like to sign a joint statement to spontaneously exchange CbC reports submitted by their respective taxpayers. The Competent Authorities desire to
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 19 January 2018, the Treasury Department and the Internal Revenue Service issued additional guidance (Notice 2018-13) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreJamaica: TAJ revised the income tax return forms and due date
Tax Administration Jamaica wishes to advise that the deadline to file Final Income Tax Returns forms for the year of assessment 2017 has been extended until 15 March 2018. TAJ also stated that the revisions are improvements which will allow the
See MoreEcuador reforms tax law for 2018
On 29 November 2017, Ecuador has enacted a new law published in Official Gazette-150 that reforms tax laws, effective as of 1 January 2018. Corporate income tax The new law increases the corporate income tax rate from 22% to 25% and withholding
See MoreArgentina: AFIP publishes a Resolution to amend rules on capital gains tax of nonresidents
The Argentine Tax Authorities (“AFIP”) published General Resolution No 4190/2018 (“GR 4190”) on January 12, 2018 in the Official Gazette and issued it on January 11, 2018. As a result of the recent tax reform enacted through Law 27,430, a
See MoreCanada: Trade complaint files against US
Canada filed an official request for consultations document, which was circulated on January 10, 2018, to other World Trade Organization (WTO) members concerning certain laws, regulations and other measures maintained by the US with respect to
See MoreColombia issues regulations on CbC reporting notification requirement
The tax authority of Colombia (DIAN) published Decree 2120 of 15 December 2017 concerning the obligation for taxpayers to inform the tax authorities whether they are required to file the Country-by-Country (CbC) report. The CbC report filing
See MoreUS: IRS issues guidance for computing the “transition tax” on foreign earnings
On 29 December 2017, the Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the “transition tax” under recent tax legislation enacted on Dec. 22, 2017. In general, newly-issued
See MoreUS: The Nation’s tax season will begin 29 January 2018
On January 4, 2018, the Internal Revenue Service announced that tax collection will begin on Monday, January 29, 2018, and taxpayers are reminded of certain tax credits that the refunds will not be available until the end of February. The IRS will
See MoreArgentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreCanada: Deadline extends for the access of Voluntary Disclosures program
The Canada Revenue Agency (CRA) has extended the deadline for taxpayers to access the current Voluntary Disclosures Program (VDP). In order for a taxpayer to be eligible for the VDP relief outlined in Information Circular IC00-1R5, unintentional
See MorePGA Highlights: December 2017
In the United States the following events have taken place under the several PGA during the month of December 2017. Agencies Summary Federal Register Notice of request for panel review: A request for panel review was filed on behalf of the
See MoreUnited States: ADD/CVD Roundup for December 2017
Following table shows the Federal Register notices related to ADD/CVD cases for December 2017 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Postponement of Final Determinations of Sales in Less Than
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
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