US: IRS has released its annual report for 2013 on APAs
The annual report on the advance pricing and mutual agreement (APMA) program was issued by the IRS on 27 March 2014. The APMA program takes place as part of the work of the Large Business and International Division of the IRS. The report shows that
See MoreSwitzerland – Peru DTA
The double taxation agreement (DTA) between Switzerland and Peru which was originally signed on 12 September 2012 entered into force on March 10, 2014. The agreement raises the standard of tax information exchange between the two countries to the
See MoreCanada: No tax rate changes in 2014 budget
In Canada the 2014 budget for Saskatchewan was published on 19 March 2014. There is no increase in the general rate of corporate or individual tax but the dividend tax credit rate in the province is to increase. There would also be a reduction in
See MoreUS: Important information regarding intra-group services
The regulations of Treasury and IRS final intercompany service were issued on 31 July 2009. Some permitted transfer pricing methods for services are similar to the OECD methods but the services cost method and shared services arrangements are also
See MoreUS – Tax Foundation Says IRS Mandate Should Shrink
The Tax Foundation (TF) in the US has recently recommended that, as the primary function of the Internal Revenue Service should be to collect tax revenue, it would be best to move the functions of refundable tax credits outside the tax code and
See MoreUS-Iraq Hold First TIFA Meeting
A joint council set up under the Trade and Investment Framework Agreement (TIFA) between the two countries has held its first meeting. The joint council provides a forum for discussion in relation to trade issues such as the rights of employees,
See MoreUS: Talks to Expand Duty-Free IT Agreement Deadlocked
Talks in the World Trade Organization (WTO) on broadening the scope of the Information Technology Agreement continue to be deadlocked after eleven days of negotiations. The product coverage of the existing agreement has not been updated since 1996,
See MoreUS Committee Considers Middle Class Tax Burden
In the US the Senate Finance Committee has been considering policy initiatives that could help to support and expand the middle class. These measures could include improvements to the education system, initiatives to increase the level of savings
See MoreTIEA between Canada and the British Virgin Islands enters into force
The Tax Information Exchange Agreement (TIEA) between Canada and the British Virgin Islands entered into force on March 11, 2014. The TIEA provides for information exchange in relation to assessing and collecting taxes as well as in matters related
See MoreFinland and Chile Sign US FATCA
On March 5 2014 the United States signed intergovernmental agreements (IGAs) with Finland and Chile to implement the Foreign Account Tax Compliance Act (FATCA). A total of twenty four of these IGAs have so far been signed by the US in connection
See MoreEcuador: Income tax exemption on deposits and investments in securities
On 21 February 2014, the General Director of the Internal Revenue Service published Circular No. NAC-DGECCGC14-00003 in order to communicate the tax authority's application of the substance over form principle as a criterion for the application of
See MoreBrazil and Norway Sign Protocol to DTA
Brazil and Norway signed a Protocol to their double tax agreement on February 20, 2014. No further details are currently
See MoreUS: DTA Protocols between the United States and various countries
The US Senate Committee on Foreign Relations held talks on February 26, 2014, on the double taxation agreement (DTA) Protocols between the United States and Switzerland and Luxembourg, and DTAs with Hungary and Chile, as part of the nation's
See MoreUS: IRS publishes annual statistics on foreign tax credits
The US Internal Revenue Service (IRS) has published a statistical report with data of corporations that claim the US foreign tax credit (FTC). The report was published by the IRS Statistics of Income (SOI) Division based on sampling of corporate
See MoreUS – Home Office Deduction Simplified
In the internet age the number of people able to run businesses from their home has increased. The Internal Revenue Service has reminded United States taxpayers with home-based businesses that this year, for the first time, they can choose a
See MoreUS: Finland and Chile Sign FATCA Pacts
On March 5, 2014 the United States signed intergovernmental agreements (IGAs) with Finland and Chile to implement the Foreign Account Tax Compliance Act (FATCA). To date, twenty four of these bilateral agreements have been signed between the US and
See MoreUS: American Citizens Abroad Argues for Residence-Based Taxation
An organization known as American Citizens Abroad (ACA) has provided testimony to the Senate Homeland Security and Governmental Affairs Permanent Investigations Subcommittee following its recent hearing on offshore tax evasion. The ACA has
See MoreUS: 2015 Budget would increase taxes for the wealthy
The Budget 2015 proposals would reduce the United States medium-term fiscal deficit by increasing revenues, particularly on the wealthiest taxpayers, but are unlikely to reach Congress. The US deficit would fall from 3.7 percent of gross domestic
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