US: Treasury, IRS extend safe harbor for renewable energy projects
On 29 June 2021, the Department of the Treasury and the Internal Revenue Service issued guidance for taxpayers developing renewable energy projects to address delays related to the COVID-19 pandemic. In prior IRS notices, the Treasury
See MoreUS: IRS releases draft instructions Schedules K-2 and K-3 for international tax reporting
On 30 June 2021, the Treasury and the IRS released early draft instructions for the Schedules K-2 and K-3 for Forms 1065, 1120-S, and 8865 for tax year 2021 (filing season 2022). The early release drafts of the instructions provide a preview
See MoreUS: Coca-Cola requests tax court to reconsider transfer pricing dispute
On 2 June 2021, the Coca-Cola Company has requested the US Tax Court to reconsider a transfer pricing tax ruling that was given on 18 November 2020. Upon examination of the company’s 2007-2009 returns, IRS found that the company’s
See MoreUS: Nebraska cuts top corporate tax rate
On 26 May 2021, Nebraska Gov. Pete Ricketts signed Legislative Bill 432 which provides for a reduction of top corporate income tax rates over the next two years. Accordingly, for tax years beginning on or after Jan. 1, 2022, the rate will reduce
See MoreUS: Interest rates remain the same for the third quarter of 2021
On 27 May 2021, the Internal Revenue Service announced that interest rates will remain the same for the 3rd quarter beginning from 1 July 2021. The rates will be: 3% for overpayments (two (2) % in the case of a corporation),0.5% for the
See MoreUS: IRS extends e-signature authorization for submitting APA and MAP requests
On 15 April 2021, the IRS released an updated memo on e-signature requirements extending the authorization to electronically sign a large number of IRS forms until Dec. 31, 2021, and adding a number of new forms. The original authorization was
See MoreIMF: Discussion of Tax Aspects of the Fiscal Monitor Reports
On 7 April 2021 the IMF held a press briefing to discuss the latest issue of the IMF Fiscal Monitor. The Fiscal Monitor for April 2021 looks at the actions countries have taken in response to the pandemic and discusses how government policies
See MoreUS Treasury Secretary backs the OECD talks on Global Minimum Tax
On 5 April 2021 the US Treasury Secretary Janet Yellen announced that she is working with the G20 countries to reach an agreement on a global minimum corporate tax rate. This is a reference to US cooperation with the G20/OECD initiative to design a
See MoreUS: IRS releases announcement and report concerning APMAs program
On 23 March 2021, the US IRS released an advance version of Announcement 2021-6 regarding the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2020. This twenty-second report
See MoreUS: IRS publishes revised CFC practice unit guidelines
On 22 March 2021, the U.S. Internal Revenue Service has published a revised international practice unit on Receipt of Dividends or Interest from a Related CFC. This Unit was revised to include the extension of the IRC 954(c)(6) look through rule
See MoreIMF: Analysis of Fiscal Measures to Reduce US Emissions
An IMF blog of 10 March 2021 entitled A New Vision for the US Climate Agenda looks at fiscal actions that would help curb emissions. The US climate plan aims for US carbon neutrality by 2050, achieved by public funding for clean energy
See MoreUS: IRS publishes the interest rates on overpaid and underpaid tax for Q2 2021
On 2 March 2021, the Internal Revenue Service announced that interest rates for the calendar quarter beginning April 1, 2021. The rates are unchanged from the previous quarter. The rates are: 3% for overpayments (2% in the case of a
See MoreUS and Argentina sign CbC exchange arrangement
On 27 January 2021, US and Argentina have signed a competent authority agreement to exchange country-by-country reports. The purpose of the agreement is to increase international tax transparency and improve access of their respective tax
See MoreUS: IRS announces interest rates for overpaid and underpaid tax for 1st quarter of 2021
On 3 December 2020, the Internal Revenue Service announced that interest rates for overpaid and underpaid tax for 1st quarter of 2021 which are unchanged from the previous quarter. The rates will be: three (3) percent for overpayments (two (2)
See MoreUS: IRS publishes guidance on forgiven PPP loans
On 18 November 2020, the Internal Revenue Service (IRS) has published an advance version of Rev. Proc. 2020-51 that provides a safe harbor allowing a taxpayer to claim a deduction in the taxpayer’s tax year beginning or ending in 2020 (the 2020
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US and Mexico renew competent authority agreement on Maquiladoras
On 16 November 2020, the Internal Revenue Service (IRS) announced that IRS and Mexico’s Servicio de Administración Tributaria (“SAT”) have agreed to renew the Qualified Maquiladora Approach Agreement (“QMA”), a coordination
See MoreUS: IRS and Treasury issue final regulations on foreign tax credits
On 12 November 2020, the Internal Revenue Service and Treasury published in the Federal Register providing guidance related to the allocation and apportionment of deductions and foreign taxes, foreign tax re-determinations, foreign tax credit
See MoreUS and Singapore sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated page on CbC reporting jurisdiction status table. Accordingly, on 6 October 2020, U.S. and Singapore have entered into a CAA for the automatic exchange of CbC reports. Pursuant to the provisions of
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