US Tax Cuts and Jobs Act: Base Erosion Minimum Tax
The Tax Cuts and Jobs Act provides for a participation exemption in the form of a 100% deduction for the foreign-source portion of dividends received from 10%-owned foreign corporations. This deduction for dividends received can eliminate additional
See MoreUS: President signs tax cuts and jobs act
On December 22, 2017, President Donald Trump signed the Tax Cuts and Jobs Act (TCJA). On 20 December 2017, both the US Senate and the House of Representatives approved the passing of the Tax Cuts and Jobs Act with some minor changes to comply
See MoreArgentina: Comprehensive tax reform enacts
The Law No. 27430 or comprehensive tax reform was published on December 29, 2017 in the Official Gazette and it generally applies from January 1, 2018. This comprehensive tax reform bill has sent to Congress on December 14, 2017. The Ministry of the
See MoreColombia updates CbC reporting obligation
The Decree 2120 of 15 December 2017 clarifies the responsibility for Colombian taxpayers of notification of the filing of the Country by Country (CbC) Report and it is applicable as of fiscal year 2016 contains the information related to the global
See MoreChile: Tax authority publishes list of Jurisdictions with preferential tax regime
The Internal Revenue Service (Servicio de Impuestos Internos - SII) of Chile published a Resolution No. 124 of December 19, 2017 regarding list of jurisdictions that are considered to have a preferential tax regime or zero or low taxation. The list
See MoreCanada: Deadline for filing of the CbC report
According to subsection 233.8(6) of the Act, the Country-by Country (CbC) report must generally be submitted with the CRA no later than 12 months after the last day of the fiscal year to which the report relates. That means, a CbC report for the
See MoreUS: Senate passes long awaited tax reform bill
On December 3, 2017, the Senate has accepted nearly $ 1.5 trillion of Republican tax bills, a historic volume and urgent political priority for President Donald Trump and his party. The poll was 51-49, mostly along party lines. Not a single
See MorePGA Highlights: November 2017
In the United States the following events have taken place under the several PGA during the month of November 2017. Agencies Summary Federal Register General notice of ACE becoming the sole EDI system: From December 9, 2017, Automated
See MoreUnited States: ADD/CVD Roundup for November 2017
Following table shows the Federal Register notices related to ADD/CVD cases for November 2017 in United States. Country Product Investigations Case Number Details Belarus Certain Carbon and Alloy Steel Wire Rod Affirmative Final Determinations
See MoreMexico releases online platform for Transfer Pricing Informative Returns
On 1 November 2017, the Mexican Tax Administration (SAT) released the online platform and digital formats for the new informative statements for taxpayers required to submit the new Transfer Pricing Informative Returns under Article 76-A of the
See MoreUS: Senate finance committee proposes to tax cut for US beverage industry
The Senate Finance Committee included provisions to reduce the tax burden on US brewers and distilleries for two years, and to allow wine producers a permanent tax cut. The proposal lowers the tax on beer to $ 16 a barrel on the first six million
See MoreChile: Government sets anti-dumping duties on Chinese steel grinding rods
The Chilean government has imposed final anti-dumping duties on imports of steel grinding rods from China under the country’s anti-distortions
See MoreEcuador: President signs decree for reduction of advance tax payment
On 20 November 2017, Mr. Lenín Moreno, the President of Ecuador signed Executive Decree No. 210, regarding decrease of income tax advance payments corresponding to the tax year 2017. The Decree provides a 100% reduction for individuals and
See MorePeru: Amendments made to local file reporting requirement
The Peruvian Government issued transfer pricing (TP) regulations (Supreme Decree N° 333-2007-EF) on 17 November 2017 with detail guidance on the preparation and submission of the country-by country (CbC) report. According to amendments made to
See MoreArgentina: General Resolution 4157-E publishes for updating Compliance requirement
The General Resolution 4157-E of the Federal Tax Administration was published on November 17, 2017 in the official gazette for updating the requirements and formalities listed in General Resolution 2681 to be complied by tax-exempt entities. These
See MoreU.S. and Italy sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Italy have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreUS: IRS issues a correction on tax regulations
The US Tax Administration (IRS) issued a correction to tax ordinances (TD 9803) on November 15 regarding the transfer of ownership of foreign corporations. These rules, which were published on 16 December 2016, retrospectively removed the exemption
See MoreCosta Rica: Tax administration publishes draft resolution on CbC reporting
On 26 October 2017, Costa Rica’s tax administration released a draft version of a resolution that would require multinational enterprises (MNEs) to file a country-by-country (CbC) report. According to draft resolution, all Costa Rican tax resident
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