Canada: New guidance regarding contemporaneous documentation
The CRA’s updated Transfer Pricing Memorandum (TPM-05R) clarifies the CRA’s process for requesting contemporaneous documentation and includes specifically four new sections, such as method of delivery, three-month delivery, documents provided to
See MoreIRS warns filing deadlines for US Expats
US citizens and resident living overseas who are eligible for an automatic two-month extension after the regular April 15 tax filing date must file their 2013 federal income tax returns by June 16. Since 15 June is Sunday this year taxpayers get one
See MoreTurkey enlisted as having FATCA in effect
Turkey has reached an intergovernmental agreement (IGA) with the United States to execute the Foreign Account Tax Compliance Act (FATCA), and has agreed to be listed on the website of the US Treasury Department as a jurisdiction that is supported as
See MoreMexico-UAE: Income Tax Treaty ratified by Mexico
Mexico has ratified the income tax treaty between Mexico and the United Arab Emirates on May 26, 2014 which was signed on November 20, 2012 by way of Presidential
See MoreCanada -Australia ITT regarding income of employee on a short-term secondment
The Australian Taxation Office has published Interpretative Decision ATO ID 2014/20 on May 30, 2014 regarding the income of a non-resident individual engaged by a resident employer resident in Canada is taxable in Australia despite that the employee
See MoreCanada follows suit with US and excludes references to OECD in TP request
Canada has adopted similar position to the US and has excluded references to the OECD’s three-tier documentation in favour of its own country specific transfer pricing (TP) documentation. The Canada Revenue Agency (CRA) has reviewed its TP
See MoreUS: Poor Policy for IRS Tax Enforcement-TIGTA
The Treasury Inspector General for Tax Administration (TIGTA) recently released a report on actions taken by the United States Internal Revenue to collect individual Federal income, Social Security, and Medicare taxes unpaid by businesses were not
See MoreVenezuela – Palestine: DTA sign
Venezuela and Palestine signed a double taxation agreement (DTA) on May 17, 2014. No further details of the agreement are currently
See MoreUS: Taxpayers Giving Up US Passports As FATCA Approaches
The FATCA may be causing some taxpayers to give up their US citizenship. According to statistics issued by the US Treasury Department statistics and included in the Federal Register, more than one thousand United States taxpayers relinquished their
See MoreUS: Study Moves to Curb State Corporate Tax Incentives
The Council on Foreign Relations (CFR) in the US has recently published a memorandum that looks at the tax relief and subsidies the US federal and state governments grant every year as an incentive to attract business investment. The memorandum
See MoreUS: IRS Releases Transfer Pricing Audit Roadmap
On 14 February 2014 a Transfer Pricing Audit Roadmap was issued by the Large Business and International (LB&I) division of the IRS. This sets out the procedures in relation to the conduct of a transfer pricing audit and the timeline to follow.
See MoreUS: BEPS to Compound Global Tax Risks
Enterprises are expecting that tax risks are likely to increase more in the coming years, according to a survey of tax and finance executives in twenty five countries by the advisory firm Ernst and Young. The survey looked at the views of companies
See MoreUS Taxpayers Not Sensitive To State Income Tax Rates
The US Center on Budget and Policy Priorities has put together a report indicating that people relocating within the US do not generally regard State taxation as an important driver in their decision. This is the case even though there can be
See MoreUS Businesses Urge Two-Year Renewal of Tax Extenders
In the US the Business Roundtable (BR) has written to the Senate in relation to certain tax issues. The BR is a business grouping of CEOs from large US companies who have USD 7.4 trillion in annual revenues and together make up more than a third of
See MoreTaiwan- FATCA Agreement Expected In June 2014
Taiwan is expecting to finalize a FATCA agreement with the US by end of June 2014. The FATCA Act requires the IRS to gain information about accounts of US citizens and residents with foreign financial institutions. To ensure that this can be done
See MoreSwiss Discuss Banking Sector Tax Disputes With The US
Recent discussions between the US and Switzerland have centered on a US tax dispute settlement program for category two, three, and four banks and the current US criminal investigations into category one banks that are domiciled in Switzerland. The
See MoreMexico – Details of hydrocarbon tax in energy reform proposals
Mexico has announced proposals that would change the rules in respect of the taxation of amounts relating to hydrocarbon exploration and extraction. The rules would take effect from 1 January 2015. The additional government revenue would be raised
See MoreBrazil: Superior Court Rules in Vale CFC Appeal
The Superior Court of Justice in Brazil has arrived at a decision in relation to the mining company Vale. The Court has ruled that profits of Controlled Foreign Companies (CFCs) of Vale in Belgium, Luxembourg, and Denmark would not give rise to a
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