US: IRS declares new penalty relief for taxpayers for 2020 and 2021 tax returns
On 19 December 2023, the U.S. IRS declared it is providing new penalty relief for approximately 4.7 million individuals, businesses, and tax-exempt organizations that were not sent automated collection reminder notices during the pandemic. The
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US: IRS releases draft form for corporate AMT
The U.S. IRS has released the draft Form 4626 - Alternative Minimum Tax—Corporations concerning Corporate Alternative Minimum Tax (CAMT), The Inflation Reduction Act introduced CAMT, which enforces a minimum tax of 15% on the adjusted financial
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US Treasury signs income tax treaty with Chile
On 19 December 2023, the U.S. Department of the Treasury announced the entry into force of a comprehensive income tax treaty between the United States and Chile. The Chile tax treaty is the first new comprehensive bilateral tax treaty signed by the
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US: IRS publishes guidance regarding the foreign tax credit and dual consolidated losses in relation to the GloBE model rules
The U.S. IRS has published Notice 2023-80, which outlines the guidance regarding the foreign tax credit and dual consolidated losses in relation to the GloBE Model Rules. The Notice also includes the Extension and Modification of the Temporary
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US: IRS keeps interest rates on overpaid and underpaid tax unchanged for Q1 2024
On 17 November 2023, the U.S. Internal Revenue Service announced that interest rates will remain unchanged for overpaid and underpaid tax for the calendar quarter beginning 1 January 2024. This means the interest rates remain the same as per the
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US: IRS introduces new measures to ensure tax payment by major corporations
On 20 October 2023, the US IRS announced new initiatives funded by the Inflation Reduction Act. These initiatives. These new initiatives aim to ensure that large corporations pay their outstanding taxes and intensify IRS efforts in pursuing
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US and Israel sign agreement on the exchange of CbC reports
The Internal Revenue Service (IRS) of the United States has released the competent authority arrangement concerning exchanging Country-by-Country (CbC) Reports with Israel. As per the IRS CbC Reporting Jurisdiction Status Table, this arrangement
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US: IRS announces that businesses of cash payment over $10000 must electronically file from 2024
On 30 August 2023, the U.S. Internal Revenue Service (IRS) announced that starting Jan. 1, 2024, businesses are required to electronically file (e-file) Form 8300, Report of Cash Payments Over $10,000, instead of filing a paper return. This new
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US: IRS publishes interest rates for the fourth quarter of 2023
On 25 August 2023, the U.S. Internal Revenue Service announced the interest rates for overpaid and underpaid taxes for the fourth quarter of 2023. Accordingly, the interest rates will increase for the calendar quarter beginning 1 October
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US: IRS launches paperless processing initiative
On 18 August 2023, the Internal Revenue Service (IRS) announced its initiative to launch a paperless process for filing tax returns. IRS states that taxpayers will have the option to go paperless for IRS correspondence by 2024 filing season, IRS to
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US: final regulations on carryback of consolidated net operating losses
On 12 July 2023, the U.S. Treasury Department and IRS released final regulations in the federal register that affect corporations filing consolidated returns. These regulations permit consolidated groups that acquire new members that were members
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US: IRS issues practice unit on categorization of income and taxes into proper basket for FTC
On 15 May 2023, the U.S. IRS published a practice unit regarding Foreign Tax Credit - Categorization of Income and Taxes Into Proper Basket. This Practice Unit is revised to address changes from the implementation of the Tax Cuts and Jobs Act (TCJA)
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US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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US: IRS issues guidance for the advanced manufacturing investment credit
On 14 June 2023, the Internal Revenue Service issued proposed regulations that provide guidance regarding the implementation of the elective payment provisions of the Advanced Manufacturing Investment Credit, established by the Creating Helpful
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US: Connecticut extends corporate surcharge under the budget bill 2024
On 12 June 2023, Connecticut Governor Ned Lamont of USA signed the budget bill (H.B. 6941) which includes an extension of the corporation business tax (CBT) surcharge for three years. The surcharge, set at a rate of 10%, applies to companies with
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US: IRS grants penalty relief for corporate alternative minimum tax
On 7 June 2023, the Department of Treasury and the Internal Revenue Service issued Notice 2023-42, which will grant penalty relief for corporations that did not pay estimated tax in connection with the new corporate alternative minimum tax
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US: IRS publishes interest rates remain the same for the third quarter of 2023
On 22 May 2023, the U.S Internal Revenue Service announced that interest rates for overpaid and underpaid tax for the calendar quarter beginning 1 July 2023, which will remain unchanged from the second quarter. For individuals, the rate for
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US: IRS releases interim guidance on review and acceptance of APA submissions
On 25 April 2023, the Internal Revenue Service (IRS) published a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect
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