India and USA sign inter-governmental agreement for exchange of CbC reports
On 27 March 2019, India and the US signed an Inter-Governmental Agreement for exchange of Country-by-Country (CbC) reports of multinational companies regarding income allocation and taxes paid to help check cross-border tax evasion. This
See MoreUS: APMA releases new functional cost diagnostic model (FCD model) for APA submissions
On 26 February 2019, Advance Pricing and Mutual Agreement (APMA) program of IRS, released an excel based functional cost diagnostic model (FCD Model) that is developed in connection with several prior and pending Bilateral Advance Pricing
See MoreUS: IRS announces priority guidance plans addressing many new international tax issues
On 8 November 2018, the US Treasury and IRS published its 2018–2019 Priority Guidance Plan, detailing tax guidance the government intends to focus its effort on in the coming months. The Guidance Priority List focuses resources on guidance items
See MoreSingapore signs TIEA and FATCA with the US
On 13 November 2018, the Inland Revenue Authority of Singapore has confirmed the signing of a tax information exchange agreement (TIEA) and a reciprocal FATCA Intergovernmental agreement (FATCA IGA) with the United States. The TIEA will permit
See MoreUS: Court of Appeals Withdraws Opinion in Altera case
On 8 August 2018 the US Court of Appeals (Ninth Circuit) announced that it was withdrawing its opinion of 24 July 2018 in the Altera Corp case, concerning the treatment of stock based compensation by related parties in a cost sharing arrangement
See MoreUS: IRS proposes to withdraw section 385 documentation regulations
On 21 September 2018, IRS published a document proposing to remove Section 385 from treasury regulation that was finalized in the last of the 2016. The regulations require multinationals that issue related-party debt to provide information to the
See MoreUS: IRS issues reminders relating to Form 8975 of CbC reporting
On 18 September 2018, IRS published a release reminding MNE groups on the processes of filing country-by-country reports on Form 8975. Reminder to U.S. MNEs Filing Form 8975 with no U.S. Schedule A (Form 8975) When submitting Form 8975 and Schedules
See MoreUS: IRS publishes draft form regarding the “base erosion and anti-abuse tax” (BEAT)
On 5 September 2018, the United States (US) Treasury and the Internal Revenue Service (IRS) released a draft of Form 8991 concerning the “base erosion and anti-abuse tax” (BEAT) reporting for 2018. In an effort to " level the playing field
See MoreUS: Appeal Court Overturns Altera decision on stock based compensation in CSAs
On 24 July 2018 the US Court of Appeals overturned the decision of the Tax Court in the case of Altera Corp, a case that concerned the inclusion of stock based compensation costs in cost sharing agreements (CSAs). The Appeal Court has determined
See MoreUS: Appeal Court Rules in Favour of IRS in Medtronic Case
On 16 August 2018 a US federal appeals court vacated and remanded a 2016 decision by the Tax Court in the case of Medtronic v. Commissioner. The Court of Appeals ruled that in its original decision in favour of Medtronic the Tax Court did not
See MoreUnited States: ADD/CVD Roundup for September 2018
Following table shows the Federal Register notices related to ADD/CVD cases for August 2018 in United States. Country Product Investigations Case Number Details Belgium Carbon and Alloy Steel Cut-To-Length Plate Initiation of Antidumping Duty
See MoreU.S. and Austria sign an agreement on the exchange of country-by-country reports
According to an IRS announcement on its website, the competent authorities of U.S. and Austria have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of country-by-country
See MorePGA Highlights: August 2018
In the United States the following events have taken place under the several PGA during the month of July 2018. Agencies Summary Federal Register Environmental Technologies Trade Advisory Committee (ETTAC) public meeting: This notice sets forth
See MoreUnited States: ADD/CVD Roundup for August 2018
Following table shows the Federal Register notices related to ADD/CVD cases for July 2018 in United States. Country Product Investigations Case Number Details Austria Carbon and Alloy Steel Cut-to-Length Plate Initiation of Antidumping Duty
See MoreU.S. and Croatia sign an agreement on the exchange of CbC reports
On 10 July 2018, the competent authorities of the U.S. and Croatia have concluded an arrangement on the exchange of country-by-country (CbC) reports. The competent authority arrangement (CAA) for exchange of country-by-country reports is on the
See MoreUS: IRS updates information regarding country-by-country (CbC) reporting
On 25 July 2018, Internal Revenue Service (IRS) updated the information concerning country-by-country (CbC) reporting in the United States. This includes an updated jurisdiction status table showing recently signed competent authority arrangements
See MoreUS: IRS issues new transfer pricing examination guide
On 29 June 2018, Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS released the Transfer Pricing Examination Process (TPEP) for use in transfer pricing examinations. Transfer Pricing
See MoreU.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
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