PGA Highlights: June 2018
In the United States the following events have taken place under the several PGA during the month of May 2018. Agencies Summary Federal Register Subsidy programs for softwood lumber and softwood lumber products: The Department of Commerce seeks
See MoreUS: IRS publishes new guideline for filing CbC reporting
On 18 May 2018, IRS released new guidance for filing the Form 8975 submitted by U.S. multinational enterprises (MNEs). When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975.
See MoreUS: IRS issues new advance pricing agreement (APA) template
On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).
See MoreCayman Islands: DITC released official guidance on the CbC reporting requirements
The Cayman Islands’ Department for International Tax Cooperation (“DITC”) released their official guidance on March 29, 2018 regarding the Country-by-Country (“CbC”) reporting requirements of entities that are resident in the Cayman
See MoreUS and Indonesia sign MOU on the exchange of CbC reports
On April 26, 2018, the Internal Revenue Service issued a Memorandum of Understanding (MOU) between the Competent Authorities of the United States (US) and Indonesia, which includes an announcement of the temporary suspension of Indonesia's secondary
See MoreArgentina: General Resolution 4227/2018 was published in official gazette
The Argentine Tax Authorities (“AFIP”) has published General Resolution 4227/2018 on April 12, 2018 in the official gazette. It is the regulation of the income tax on financial income obtained by beneficiaries abroad. This resolution was issued
See MoreUnited States: ADD/CVD Roundup for April 2018
Following table shows the Federal Register notices related to ADD/CVD cases for April 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Antidumping Duty Orders A-357-820 See the Federal Register
See MorePGA Highlights: April 2018
In the United States the following events have taken place under the several PGA during the month of April 2018. Agencies Summary Federal Register Subsidy programs on cheese subject to an in-quota rate of duty: This notice provides Commerce's
See MoreMexico: Government declares new decrees regarding Special Economic Zones
Mexico has declared two new decrees that providing for the initiation of two new special economic zones (SEZ) in States of Campeche and Tabasco, in the official Gazette. They are designed for where they are most needed, and to boost productive
See MoreUS: IRS publishes guidance on exhaustion of administrative remedies for foreign tax credit
On 17 April 2018, IRS published a practice unit on Exhaustion of Administrative Remedies in relation to claims for a foreign tax credit. In order for a foreign tax to be creditable under Section 901, it must be compulsory. A payment is compulsory
See MoreGreece: Parliament adopts draft bill regarding Multilateral Competent Authority Agreement
The Greek Parliament adopted a draft bill on April 19, 2018, which ratifies the Multilateral Competent Authority Agreement between Greece and United States on the exchange of country by country (CbC) reports. The CbC report is one element of
See MorePuerto Rico: Treasury Department issues Administrative Determination regarding tax returns for 2017
The Puerto Rico Treasury Department has issued Administrative Determination No. 18-07, which determines to grant all taxpayers who file a request for automatic extension to return file for 2017, a total term of 6 months, instead of the term of 3
See MoreColombia issues ruling of CFC exemption
The tax authority of Colombia (DIAN) published a ruling regarding whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a
See MoreUS: IRS issues guidance on restriction on interest deduction
On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017. In
See MoreUS: IRS issues guidance on transfer of foreign partnership interests
On 2 April 2018, the Treasury Department and the Internal Revenue Service issued guidance regarding the withholding on the transfer of non-publicly traded partnership interests under the recently enacted Tax Cuts and Jobs Act. In general, the new
See MoreUS: IRS offers guidance on ‘blended’ tax rates for corporations under the new tax reform law
On 16 April 2018, the Internal Revenue Service issued a notice that many U.S. corporations elect to use a fiscal year end instead of a calendar year end for federal income tax reporting purposes. Due to a provision in the recently enacted Tax Cuts
See MorePanama issues new form of transfer pricing information return
In accordance with Resolution No. 201-1937 of 2 April 2018, published in the Official Gazette on 9 April 2018, Panama modified Form No. 930 (V1.0), Transfer Pricing Information Return. The new form is Form No. 930
See MoreArgentina: Decree 279/2018 was published in the official gazette
The Decree 279/2018 was published on April 9, 2018 in the Official Gazette. The provisions of this decree effects from April 10, 2018. This Decree regulates the scope of the Income Tax of the financial income in order to achieve a correct
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