Argentina: AFIP publishes a Resolution to amend rules on capital gains tax of nonresidents
The Argentine Tax Authorities (“AFIP”) published General Resolution No 4190/2018 (“GR 4190”) on January 12, 2018 in the Official Gazette and issued it on January 11, 2018. As a result of the recent tax reform enacted through Law 27,430, a
See MoreCanada: Trade complaint files against US
Canada filed an official request for consultations document, which was circulated on January 10, 2018, to other World Trade Organization (WTO) members concerning certain laws, regulations and other measures maintained by the US with respect to
See MoreColombia issues regulations on CbC reporting notification requirement
The tax authority of Colombia (DIAN) published Decree 2120 of 15 December 2017 concerning the obligation for taxpayers to inform the tax authorities whether they are required to file the Country-by-Country (CbC) report. The CbC report filing
See MoreUS: IRS issues guidance for computing the “transition tax” on foreign earnings
On 29 December 2017, the Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the “transition tax” under recent tax legislation enacted on Dec. 22, 2017. In general, newly-issued
See MoreUS: The Nation’s tax season will begin 29 January 2018
On January 4, 2018, the Internal Revenue Service announced that tax collection will begin on Monday, January 29, 2018, and taxpayers are reminded of certain tax credits that the refunds will not be available until the end of February. The IRS will
See MoreArgentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreCanada: Deadline extends for the access of Voluntary Disclosures program
The Canada Revenue Agency (CRA) has extended the deadline for taxpayers to access the current Voluntary Disclosures Program (VDP). In order for a taxpayer to be eligible for the VDP relief outlined in Information Circular IC00-1R5, unintentional
See MorePGA Highlights: December 2017
In the United States the following events have taken place under the several PGA during the month of December 2017. Agencies Summary Federal Register Notice of request for panel review: A request for panel review was filed on behalf of the
See MoreUnited States: ADD/CVD Roundup for December 2017
Following table shows the Federal Register notices related to ADD/CVD cases for December 2017 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Postponement of Final Determinations of Sales in Less Than
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
See MoreUS 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
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