US: IRS, Treasury issues guidance to streamline interest capitalisation for property improvements
The guidance includes final regulations for eliminating the associated property rule and related provisions for interest capitalisation on improvements to designated property. The US Treasury and the Internal Revenue Service (IRS) have released
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US: IRS extends treaty benefits to reverse foreign hybrids subject to branch profits tax
The IRS Chief Counsel ruled that reverse foreign hybrids may qualify for reduced branch profits tax on dividend equivalent amounts attributable to treaty-eligible owners. The US Internal Revenue Service (IRS) Chief Counsel has determined that
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US: IRS retracts proposed rules on corporate divisions, reorganisations
The U.S. Treasury and IRS have withdrawn the 30 September 2025 proposed regulations on corporate separations, incorporations, reorganisations, and multi-year tax reporting for related transactions. The U.S. Department of the Treasury and the
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Ecuador, Romania sign CRS MCAA addendum
The two countries signed the addendum on 3 September 2025, updating CRS rules to cover crypto-assets and strengthen reporting and due diligence. The OECD has announced that Ecuador and Romania signed the Addendum to the Multilateral Competent
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Argentina: ARCA extends deadline for tax payment plan on incorrectly calculated losses
ARCA extends the deadline to 28 November 2025 for companies to join the payment plan for incorrectly calculated tax losses, allowing regularisation of debts with reduced down payments and up to 120 installments. The Argentine Revenue and Customs
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Ecuador: SRI updates e-filing rules for large taxpayers
Under this resolution, taxpayers must submit their declarations and pay their taxes at the same time, by the statutory due date. Ecuador’s tax authority (SRI) issued Resolution NAC-DGERCGC25-00000030 on 23 September 2025, updating the
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Chile: SII extends deadline for digital platforms to confirm user tax details
The deadlines for platforms to verify users’ business registrations with the SII and for DIPs to validate and submit this information have been postponed: verification now starts 2 January 2026, DIP validation by 1 January 2026, and the final
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Brazil, US sign agreement on automatic tax data sharing
The arrangement creates a formal system for Brazil and the U.S. to automatically share tax information under their 2007 agreement. The U.S. Internal Revenue Service (IRS) and Brazil have published a competent authority arrangement on 27 August
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US: Court of Appeals determines tax authorities cannot reallocate income beyond a taxpayer’s legal entitlementÂ
The IRS sought to reallocate an additional USD 23.7 million in royalties to 3M under the arm’s-length standard, despite the company’s Brazilian subsidiary being legally limited to paying only USD 5.1 million. The US Court of Appeals for the
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US: Trump weighs major tariff relief to boost US auto manufacturing
The proposal aims to cut costs for major U.S. carmakers by rewarding companies that assemble vehicles domestically, supporting Trump’s job creation goals. US President Donald Trump is considering a major tariff relief plan aimed at boosting US
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Chile: SII revises UAE’s status on its preferential tax regimes listÂ
This resolution repeals Resolution Ex. SII No. 61-2025, which had set 1 June 2023 as the removal date, and confirms that the UAE is not considered to have a preferential tax regime under the Income Tax Law (LIR). Chile’s tax administration
See MoreChile: SII revises 2026 luxury tax values for aircraft, yachts, vehicles
Resolution Ex. SII No. 121-2025 updates the fair market values for helicopters, airplanes, yachts, and vehicles subject to the 2% luxury goods excise tax for 2026. Chile’s tax administration (SII) has published Resolution Ex. SII No. 121-2025
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Canada: CRA simplifies tax adjustments through revised voluntary disclosures program
The VDP lets taxpayers voluntarily correct past tax errors for potential penalty and interest relief, but only for tax years overdue by at least one year. The Canada Revenue Agency (CRA) announced, on 10 September 2025, that it will update the
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US: IRS extends filing, payment deadlines for taxpayers impacted by ongoing conflict in Israel
IRS is providing separate but overlapping relief to taxpayers who may be unable to meet a tax-filing or tax-payment obligation, or may be unable to perform other time-sensitive tax-related actions. The US Internal Revenue Service (IRS) announced,
See MoreUS: Treasury, IRS issue guidance on rural opportunity zone investments under the One, Big, Beautiful Bill
The guidance provides clarification on rural Qualified Opportunity Zone investments, which offer tax incentives to encourage economic growth and job creation in underserved areas. The US Department of the Treasury and the Internal Revenue Service
See MoreUS: IRS issues interim guidance on corporate alternative minimum tax (CAMT)
The two notices, Notice 2025-46 and Notice 2025-49, on 30 September 2025, provide interim guidance on the corporate alternative minimum tax (CAMT). ​​ The US Internal Revenue Service (IRS) issued two notices, Notice 2025-46 and Notice
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Peru: BEPS MLI enters into force
Peru’s BEPS MLI entered into force on 1 October 2025 to curb tax treaty abuse and base erosion by multinationals. The Multilateral Convention on Tax Treaty Measures to Counter Base Erosion and Profit Shifting (MLI) has entered into force in
See MoreChile: SII announces filing deadlines for FY 2026 annual tax return forms
Chile’s Tax Authority (Servicio de Impuestos Internos – SII) has issued Resolution Ex. SII No. 123-2025 on 25 September 2025, announcing the official filing schedule for annual tax return forms due in fiscal year (FY) 2026. Annual tax
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