US: IRS issues additional guidance for computing the “transition tax” on foreign earnings

10 April, 2018

On 2 April 2018, the Treasury Department and the Internal Revenue Service published additional guidance (Notice 2018-26) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax

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United States: ADD/CVD Roundup for March 2018

02 April, 2018

Following table shows the Federal Register notices related to ADD/CVD cases for March 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Final Determination of Sales at Less Than Fair Value and Final

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PGA Highlights: March 2018

02 April, 2018

In the United States the following events have taken place under the several PGA during the month of March 2018. Agencies Summary CBP CBP releases E-Commerce Strategy: The U.S. Customs and Border Protection released its e-commerce strategy on

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US: IRS publishes interest rate for the second quarter of 2018

13 March, 2018

On 7 March 2018, The Internal Revenue Service announced that interest rates for overpaid and underpaid increased for the calendar quarter beginning April 1, 2018. The rates are 5% for both overpayments and underpayments by individuals, and 4% and 5%

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PGA Highlights: February 2018

05 March, 2018

In the United States the following events have taken place under the several PGA during the month of February 2018. Agencies Summary Federal Register Annual listing of foreign government subsidies on articles of cheese: This notice has been

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United States: ADD/CVD Roundup for February 2018

04 March, 2018

Following table shows the Federal Register notices related to ADD/CVD cases for February 2018 in United States. Country Product Investigations Case Number Details Belarus Carbon and Alloy Steel Wire Rod Notice of Correction to Antidumping Duty

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US: IRS files pre-trial memorandum against Coca Cola in transfer pricing dispute

03 March, 2018

On 15 February 2018 the IRS filed a pre-trial memorandum against The Coca Cola Company on the grounds that the transfer pricing methods used by Coca Cola were not in compliance with the arm’s length standard under section 482. The case relates to

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US: IRS increases the fees for advance pricing agreements

26 February, 2018

On 6 February 2018, the Internal Revenue Service (IRS) announced that fees for Advance Pricing Agreements (APAs) are expected to increase in a two-step process. For APA requests submitted after June 30, 2018, the fees will increase as follows:

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United States: ADD/CVD Roundup for January 2018

04 February, 2018

Following table shows the Federal Register notices related to ADD/CVD cases for January 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Countervailing Duty Orders C-357-821 See the Federal Register

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US: President signs Tax Cuts and Jobs Act

01 February, 2018

Congress has passed the Tax Cuts and Jobs Act(the Act), and the President signed it on December 22, 2017. The most important changes in the area of corporate taxation are: Main corporate tax rate:  Under the new Act, the corporate tax rate

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PGA Highlights: January 2018

01 February, 2018

In the United States the following events have taken place under the several PGA during the month of January 2018. Agencies Summary Federal Register Scheduling of upcoming public hearing: The Commission has scheduled a public hearing for March

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US: IRS issues guidance on penalties for understatement of income tax

31 January, 2018

On 29 January 2018, the US Internal Revenue Service (IRS) has issued the Revenue Procedure 2018-11 to recognize circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or position is adequate for the

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IMF says tax reform of US boost global growth

24 January, 2018

On 22 January 2018, the International Monetary Fund revised upwards its forecast for global economic growth in 2018 and 2019, pointing out that US tax cuts would boost investment in the world's largest economy and help its major trading partners.

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India: CBDT signed first bilateral APA with US

23 January, 2018

On 5 January 2018, the Indian Central Board of Direct Taxes (CBDT) signed the first bilateral advance pricing agreement (APA) with the United States. The CBDT has also indicated that there are many more bilateral APAs with the United States

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US: IRS releases directives on transfer pricing examinations

22 January, 2018

On 12 January 2018, the IRS Large Business and International (LB&I) division publicly released a set of five LB&I directives as guidance with respect for examinations of transfer pricing issues. Interim Instructions on Issuance of

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US: IRS updates information concerning country-by-country (CbC) reporting

22 January, 2018

On 18 January 2018, the IRS issued a release announcing updates and information regarding country-by-country (CbC) reporting requirements in the United States. Under the update list, IRS publishes new content on Country-by-Country (CbC) reporting

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US: Government signs joint statement on exchange of country-by-country tax reports with France

22 January, 2018

On January 12, the IRS announced on its website that the US and French competent authorities would like to sign a joint statement to spontaneously exchange CbC reports submitted by their respective taxpayers. The Competent Authorities desire to

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US: IRS issues additional guidance for computing the “transition tax” on foreign earnings

21 January, 2018

On 19 January 2018, the Treasury Department and the Internal Revenue Service issued additional guidance (Notice 2018-13) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax

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