US: 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
See MoreU.S. and Germany sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated information on CbC reporting jurisdiction status table. Accordingly, on 14 August 2020, U.S. and Germany sign an agreement on exchange of Country-by-Country reports. Each Competent Authority intends
See MoreUS: IRS updates parameters for APA and MAP
On 28 October 2020, the US Internal Revenue Service (IRS) published that it is updating parameters that the Advance Pricing and Mutual Agreement program (APMA), a representative office of the U.S. competent authority, will follow in implementing
See MoreUS: Final Withholding Regulations on Transfer of Partnership Interest by Foreign Partner
On 7 October 2020, the IRS issued final regulations on the withholding rules for transfers of partnership interests by foreign transferors. A gain on the sale or disposition by a non-US partner of an interest in a partnership that engaged in a
See MoreUS: IRS releases final regulations on interest expense deduction limitation
On 14 September 2020, the US IRS published the final regulations for the business interest expense deduction limitation published in the Federal Register. The final regulations vary slightly from the document released on IRS.gov on July 28,
See MoreUS: IRS announces tax relief for tropical storm ‘Isaias’ victims in Puerto Rico
On 10 September 2020, the Internal Revenue Service (IRS) has announced tax relief for tropical storm ‘Isaias’ victims in Puerto Rico. IRS states that tax returns and makes tax payments for individual and business has been extended until 30
See MoreUS: IRS announces interest rates for overpaid and underpaid tax for Q4
On 3 September 2020, the Internal Revenue Service announced that interest rates will remain the same for the calendar quarter beginning October 1, 2020. The rates will be: 3% for overpayments (2% in the case of a corporation);0.5% for the
See MoreUS: IRS publishes additional guidance on base erosion and anti-abuse tax
On 1 September 2020, the Internal Revenue Service issued final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT). To limit profit-shifting, the Tax Cuts and Jobs Act (TCJA) added a new tax, the BEAT. The
See MoreUS: North Carolina announces voluntary corporate transfer pricing resolution initiative
On 30 July 2020, the North Carolina Department of Revenue announced that it is implementing a voluntary initiative to expedite the resolution of corporate intercompany pricing issues. The purpose of this initiative is to fairly and consistently
See MoreUS: IRS publishes revised practice unit on dividends or interest from a related CFC
On 29 July 2020, the U.S. IRS published a revised international practice unit on the Receipt of Dividends or Interest from a Related CFC. The practice unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with
See MoreUS and Switzerland sign competent authority arrangement on implementation of arbitration
On 28 July 2020, U.S. and Switzerland signed an agreement for the implementation of the arbitration process provided for in Article 25 (Mutual Agreement Procedure) of the 1996 income tax treaty between the two countries as amended by the 2009
See MoreUS: IRS issues final regulations and other guidance on business interest expense deduction limitation
On 28 July 2020, the Internal Revenue Service issued final regulations regarding the provision of the Tax Cuts and Jobs Act that limits the deduction for business interest expense, including basic statutory amendments made by the CARES Act. For
See MoreUS: Treasury Department and IRS issue guidance for group’s net operating losses
On 2 July 2020, the Department of the Treasury and the Internal Revenue Service issued proposed regulations and temporary regulations that provide guidance for consolidated groups regarding net operating losses (NOLs). The Tax Cuts and Jobs
See MoreUS: Supreme Court Will Not Review Ninth Circuit Decision in Altera case
On 22 June 2020 the US Supreme Court announced that it would not review the Ninth Circuit panel decision in the Altera case. The Ninth Circuit decision of 7 June 2019 that upheld the validity of US cost sharing regulations therefore still
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