US: BOI reporting still voluntary after Supreme Court lifts injunction
The US Supreme Court on 23 January 2025 approved the government's request to lift a nationwide injunction previously issued by a federal judge in Texas. The US Treasury Department's Financial Crimes Enforcement Network (FinCEN) has issued an
See MoreUS: Supreme Court rejects Disney, IBM tax appeals on foreign royalties
The US Supreme Court has declined to review two notable cases from Disney on 21 January 2025, upholding a New York ruling that bars companies from deducting payments to foreign affiliates for intellectual property under a state law from 2003 to
See MoreUS: Treasury to probe foreign countries’ tax discrimination against American citizens, corporations
Republicans on the US House Ways and Means Committee have proposed new legislation on 22 January 2025, which aims to tighten oversight of foreign tax policies. The bill shall require the Treasury Department to identify extraterritorial and
See MoreUS: Senate Finance, Foreign Relations Committees propose Bill to expedite double-tax relief on US-Taiwan cross-border investment
US Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon), with US Senate Foreign Relations Committee Chairman Jim Risch (R-Idaho) and Ranking Member Jeanne Shaheen (D-New Hampshire) has introduced a
See MoreUS: IRS, Treasury revise rules for determination of taxable income or loss and foreign currency gain or loss for a qualified business unit
The US Internal Revenue Service (IRS) and Department of the Treasury has published a correction on 17 January 2025 concerning the final regulations on Taxable Income or Loss and Currency Gain or Loss with Respect to a Qualified Business Unit (QBU),
See MoreUS: IRS launches programmes to streamline alternative dispute resolution
The US Internal Revenue Service (IRS) issued IR-2025-14 on 15 January 2025 announcing three pilot programmes that will test changes to existing Alternative Dispute Resolution (ADR) programmes. IRS ADR programmes are designed to help taxpayers
See MoreUS: House of Representatives passes Taiwan Tax Relief Act
The US House of Representatives approved Bill H.R. 33 – also known as the United States-Taiwan Expedited Double-Tax Relief Act – on 15 January 2025. This legislation aims to relieve double taxation in Taiwan by authorising a tax treaty
See MoreUS: Trump Administration withdraws from OECD Global Tax Deal commitment
The Trump administration released a memorandum to the Treasury Secretary and the US Trade Representative instructing them to withdraw from the OECD’s “Global Tax Deal” on 20 January 2025. This initiative includes the Pillar One and Pillar Two
See MoreUS releases expiring federal tax provisions list 2024-2034
The US Joint Committee on Taxation has published the List of Expiring Federal Tax Provisions for 2024-2034 on 9 January 2025. This document lists Federal tax provisions that expired in 2024 or are scheduled to expire in the future. Years in which
See MoreUS: Treasury, IRS finalise rules on micro-captive transactions
The US Department of the Treasury and the Internal Revenue Service (IRS) released the final regulations (TD 10029) identifying transactions that are the same as, or substantially similar to, certain micro-captive transactions as listed transactions,
See MoreIMF: Briefing on the World Economic Outlook
In the briefing on the latest World Economic Outlook on 17 January 2024, the Director of the IMF’s Research Department confirmed that global growth is projected to remain steady at 3.3% in 2025 and 2026. Globally, inflation is expected to decline
See MoreIMF Updates World Economic Outlook
On 17 January 2025 the IMF published the update to the World Economic Outlook, with the subtitle Global Growth: Divergent and Uncertain. The update notes that global growth is expected to remain stable at 3.3% in both 2025 and 2026, below the
See MoreCzech Republic posts CAA text for CbC reporting with the US
The Czech Republic’s Ministry of Finance has published the text of a Competent Authority Agreement (CAA) concerning the exchange of country-by-country (CbC) reports with the United States on 9 January 2025. This agreement between the two
See MoreUS: IRS, Treasury finalise rules on dual consolidated losses and disregarded payments
The US Department of Treasury and the Internal Revenue Service (IRS) have released the final Rules on Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, which were officially published in the Federal Register on 14 January
See MoreUS: Michigan enacts R&D credit law
Michigan’s governor has approved the legislation (2023-HNB-5100) on 13 January 2025, which introduces a research and development (R&D) tax credit in Michigan. This new incentive will take effect for tax years beginning on or after 1 January
See MoreUS, France announce spontaneous exchange of CbC reports for 2024-2025
The US Internal Revenue Service (IRS) in collaboration with France's competent authority, has issued a joint statement outlining plans for the spontaneous exchange of country-by-country (CbC) reports. This initiative will apply to fiscal years
See MoreUS: IRS, Treasury finalise rules on digital and cloud transactions
The US Internal Revenue Service (IRS) and the Treasury Department have released final regulations addressing the Classification of Digital Content Transactions and Cloud Transactions. The regulation was published in the Federal Register on 14
See MoreUS: California grants tax relief for Los Angeles wildfire victims
California Governor Newsom announced that the California Franchise Tax Board (FTB) will provide state disaster tax relief for taxpayers and businesses affected by the recent wildfires in Los Angeles on 11 January 2025. “California is taking
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