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
See MoreUS: 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
See MoreUS: 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
See MoreUS: 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
See MoreUS: IRS issues interim guidance on review and acceptance of advance pricing agreement (APA) submissions
The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International
See MoreUS and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
See MoreUS: Tax proposals under the budget for fiscal year 2024
On 9 March 2023, U.S. President Joe Biden released the Fiscal Year 2024 Budget introducing following tax proposal. Ensures Corporations Pay Their Fair Share: The Budget includes an increase to the rate that corporations pay in taxes on their
See MoreUS: IRS extends the tax relief measures for taxpayers in disaster area
On 24 February 2023, the Internal Revenue Service announced that tax relief measures for disaster area taxpayers in California, Alabama and Georgia has been further extended to 16 October 2023. Previously, the deadline had been postponed to May 15
See MoreUS: IRS and Treasury issue final regulations on e-file for businesses
On 21 February 2023, the Department of the Treasury and the Internal Revenue Service issued final regulations T.D. 9972 amending the rules for filing returns and other documents electronically (e-file). These regulations will require certain filers
See MoreUS: IRS publishes interest rates on overpaid and underpaid tax for Q2 of 2023
On 13 February 2023, the Internal Revenue Service announced the interest rates for the calendar quarter beginning April 1, 2023. The rate will remain same as first quarter. Here is a complete list of the new rates: 7% for overpayments (payments
See MoreGermany: Lower house of parliament adopts CbC exchange agreement with USA
On 9 February 2023, the German lower house of parliament (Bundestag) has approved a law to ratify the pending agreement with the USA on the exchange of CbC reports. The agreement was signed on 14 August 2020. The agreement will enter into force when
See MoreUS: Tax court approves agreement resolving APA cancellation case
On 3 February 2023, the US Tax Court issued a rule approving an agreement between Eaton Corporation and the IRS to adjust Eaton's tax bill for 2005 and 2006 to USD 8.8 million. The proposal stems from lengthy litigation in both the Tax Court and
See MoreUS: IRS invites to comments on CbC report form
As part of its continuing effort to reduce paperwork and respondent burden, on 5 January 2023, the Internal Revenue Service invited the general public and other federal agencies to take this opportunity to comment on proposed and/or continuing
See MoreUS businesses not obligated to report digital asset transactions until regulations are established
On 16 January 2024, the US Treasury Department and IRS declared that businesses in the US are not required to report transactions involving digital assets the same way as they must report the receipt of cash until the Treasury and IRS issue
See MoreUS: IRS publishes join statement with France on exchange of CbC reports for FY 2022-2023
On 7 December 2022, 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
See MoreUS: IRS publishes interest rates on overpaid and underpaid tax for Q1 of 2023
On 29 November, the Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning January 1, 2023. For individuals, the rate for overpayments and underpayments will be 7% per year, compounded daily, up
See MoreUS: IRS issues guidance related foreign tax credit
On 22 November 2022, the U.S. Internal Revenue Service issued a guidance relating to the foreign tax credit, including guidance with respect to the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery
See MoreGermany: Federal Cabinet approves CbC reports exchange agreement with US
On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. The competent
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