US: 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
See MoreUS: IRS releases interest rates on overpaid and underpaid tax for third quarter
On 4 June 2020, the U.S. Internal Revenue Service announced that interest rates for overpaid and underpaid tax for the calendar quarter beginning 1 July 2020, which are reduced by 2% compared to the previous quarter. The rates will
See MoreUS: IRS announces to change the procedures for filing MAP and APA
On 11 May 2020, IRS officials announced certain modifications to procedures for filing documents under Rev. Proc. 2015-40, 2015-35 IRB 236 (mutual agreement procedure (MAP) requests), and Rev. Proc. 2015-41, 2015-35 IRB 263 (advance pricing
See MoreUS: Tax court ruled in favor of the IRS for Whirlpool vs Commissioner case
On 5 May 2020, the US tax court made a decision in favor of the IRS a case involving the Whirlpool Financial Corp. and related foreign affiliate corporations. The Court upheld the Internal Revenue Service's (IRS) application of the Subpart F
See MoreUS: IRS publishes FAQs on transfer pricing documentation best practices
On 14 April 2020, the United States (US) Internal Revenue Service (IRS) has posted on its website new frequently asked questions (FAQs) outlining best practices and common error in preparing transfer pricing documentation. The IRS states that
See MoreCOVID-19: US IRS extends additional key tax deadlines for certain individuals and businesses
On 9 April 2020, the Department of Treasury and the Internal Revenue Service published a notice that extends additional key tax deadlines for individuals and businesses. In March 2020, the IRS announced that taxpayers generally have until July
See MoreCOVID-19: US passes Coronavirus Aid, Relief, and Economic Security (CARES) Act
On 19 March 2020, the US Senate Finance Committee submitted proposals for the third round of legislative measures in response to the economic impact of the coronavirus disease (COVID-19) pandemic. The Coronavirus Aid, Relief, and Economic Security
See MoreUS: IRS extends federal income tax filing deadline from 15 April to 15 July 2020
On 21 March 2020, the Treasury Department and Internal Revenue Service announced that the federal income tax filing due date is automatically extended from April 15, 2020, to July 15, 2020. Taxpayers can also defer federal income tax payments
See MoreFrance and the US agree deal on digital tax
Following talks with the US on taxation of digital companies France has agreed to stop delay collection of its planned digital tax, although the liability for the tax will still accrue. France is planning to impose a 3% digital services tax on
See MoreUS: IRS issues final regulations on the base erosion and anti-abuse tax
On 2 December 2019, the Internal Revenue Service (IRS) issued final regulations and proposed regulations on the base erosion and anti-abuse tax. The Tax Cuts and Jobs Act (TCJA) made major changes to the tax law including revamping the U.S.
See MoreUS: IRS publishes interest rate on overpaid and underpaid for first quarter of 2020
On 6 December 2019, The Internal Revenue Service announced interest rates for overpayments and underpayments that will remain the same for the calendar quarter beginning January 1, 2020. Accordingly, 5% for overpayments (4% in the case of a
See MoreUS: IRS and treasury issue final regulations on the foreign tax credit
On 2 December 2019, the Internal Revenue Service issued final regulations on the Foreign Tax Credit, a long-standing tax benefit that generally allows individuals and businesses to claim a credit for income taxes paid or accrued to foreign
See MoreUS: IRS issues a notice requesting comments on CbC form
On 6 November 2019, the US Internal Revenue Service (IRS) published a notice requesting comments concerning IRS Form 8975 regarding CbC report. The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent
See MoreUS: Court of Appeals denies the petition for rehearing of Altera Corp. v. Commissioner
On 12 November 2019, the Ninth Circuit denied the taxpayer’s motion for rehearing en banc through issued an order. The order means that the Ninth Circuit will not reconsider its June 7, 2019 decision upholding the validity of the SBC rule in Reg.
See MoreUS: Treasury department issues regulations removing documentation requirements
On 31 October 2019, the US treasury department issued final regulations (TD 9880), repealing section 385, which sets out minimum documentation requirements that must normally be met in order for certain related-party interests in a corporation to
See MoreUS: Tax Court issues an opinion in the case of Eaton Corp. v. Commissioner regarding APA
On 28 October 2019, the U.S. Tax Court published an order in the case of Eaton Corp. v. Commissioner related to advance pricing agreements (APAs). In that case, Eaton Corporation (P-Petitioner) and Commissioner of Internal Revenue
See MoreUS: IRS publishes final and proposed regulations on new 100% depreciation
On 13 September 2019, the Treasury Department and the Internal Revenue Service published final regulations and additional proposed regulations under section 168(k) of the Internal Revenue Code on the new 100% additional first year depreciation
See More