US: Tax court issues an opinion regarding transfer pricing method
On 18 August 2022, the U.S. Tax Court issued an opinion on the transfer pricing case of Medtronic, Inc. v. Commissioner, T.C. Memo 2022-85. Facts of the case Medtronic US is the parent company of a global medical device company that
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US Inflation Reduction Act includes 15% corporate minimum tax on book income
On 16 August 2022, the President of the United States (US), Joe Biden, signed the Inflation Reduction Act (the Act) into law providing a 15% corporate alternative minimum tax (CAMT) based on book income. The Corporate Alternative Minimum Tax (CAMT)
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US: IRS publishes interest rates on overpaid and underpaid tax for Q4 of 2022
On 15 August 2022, the Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning October 1, 2022. For individuals, the rate for overpayments and underpayments will be 6% per year, compounded daily, up
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IMF Report Looks at the US Economic Situation
On 12 July 2022 the IMF published a report following consultations with the US under Article IV of the IMF’s articles of agreement. The US has recovered quickly from the economic shock caused by the pandemic although the recovery of demand,
See MoreUS: IRS publishes interest rates on overpaid and underpaid tax for Q3 of 2022
On 20 May 2022, the Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning July 1, 2022. The rates will be: 5% for overpayments (4% in the case of a corporation).2.5% for the portion of a
See MoreUS: Treasury Department releases tax proposals from Budget 2023
On 28 March 2022, the Treasury Department of United States published details of tax proposals in the administration’s budget recommendations for FY 2023 in the “GreenBook.” The Greenbook describes following tax measures related to corporate
See MoreUS: IRS releases interest rates on overpaid and underpaid tax for 2Q of 2022
On 23 February 2022, Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning April 1, 2022. The rates will be: 4% for overpayments (3% in the case of a corporation);1.5% for the portion of a
See MoreTurkey ratifies CAA regarding CbC exchange arrangement with US
On 14 February 2022, the Turkish Revenue Administration has issued Presidential Decision No. 5191 in the Official Gazette, through which Turkey ratifies the competent authority arrangement (CAA) on the exchange of country-by-country (CbC) with US.
See MoreUS: Tax Court refuses for reconsideration in transfer pricing dispute
On 26 October the US Tax Court has denied Coca-Cola’s motion for leave to file out of time a motion for reconsideration on the grounds that the application for leave would be “futile” as the court would, since the court will ultimately
See MoreUS and Turkey sign CAA regarding CbC exchange arrangement
On 24 November 2021, US and Turkey have signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. A CbC report is intended to be first exchanged with respect to Fiscal Years of MNE Groups commencing on or after 1
See MoreUS and India reach agreement on ‘equalization levy’ digital services tax
On 24 November 2021, the United States and India concluded an agreement on a transitional approach to the treatment of the current Indian E-commerce Equalization Levy (EL) in the transition period prior to the full implementation of Pillar 1
See MoreUS and Turkey sign digital service tax agreement
On 22 November 2021, the U.S. treasury department announced that the United States and Turkey have reached a political agreement with Turkey on the treatment of taxes on digital services (DST) in the transition period prior to the full
See MoreUS: IRS releases interest rates on overpaid and underpaid tax for Q1 of 2022
On 23 November 2021, the Internal Revenue Service announced that interest rates will remain the same for the calendar quarter beginning January 1, 2022. The rates will be: 3% for overpayments (two (2) percent in the case of a corporation),0.5%
See MoreCyprus clarifies bilateral agreement with US on exchange of CbC report
On 7 October 2021, the Cyprus Tax Department informs all legal entities and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
See MoreUS: CRS releases report on tax provisions in the “Build Back Better Act”
On 28 September 2021, the U.S. Congressional Research Services (CRS) has published a report on the tax provisions in the legislative recommendations for the budget reconciliation legislation, also known as the “Build Back Better Act. The
See MoreUS: IRS publishes interest rates for Q4 maintaining the same as 3rd quarter
On 25 August 2021, the U.S. Internal Revenue Service announced interest rates for the fourth quarter which remains the same as third quarter. The fourth quarter will be started from 1 October 2021 with the following rates: 3% for overpayments
See MoreUS: IRS publishes joint statement with Germany on the exchange of CbC reports
The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the Germany on the implementation of the spontaneous exchange of Country-by-Country Reports
See MoreUS: IRS publishes joint statement with France on the exchange of CbC reports
The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United states of America and the competent authority of the French republic on the implementation of the spontaneous exchange of country-by-country
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