US: IRS publishes guidance on exhaustion of administrative remedies for foreign tax credit
On 17 April 2018, IRS published a practice unit on Exhaustion of Administrative Remedies in relation to claims for a foreign tax credit. In order for a foreign tax to be creditable under Section 901, it must be compulsory. A payment is compulsory
See MoreGreece: Parliament adopts draft bill regarding Multilateral Competent Authority Agreement
The Greek Parliament adopted a draft bill on April 19, 2018, which ratifies the Multilateral Competent Authority Agreement between Greece and United States on the exchange of country by country (CbC) reports. The CbC report is one element of
See MoreUS: IRS issues guidance on restriction on interest deduction
On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017. In
See MoreUS: IRS issues guidance on transfer of foreign partnership interests
On 2 April 2018, the Treasury Department and the Internal Revenue Service issued guidance regarding the withholding on the transfer of non-publicly traded partnership interests under the recently enacted Tax Cuts and Jobs Act. In general, the new
See MoreUS: IRS offers guidance on ‘blended’ tax rates for corporations under the new tax reform law
On 16 April 2018, the Internal Revenue Service issued a notice that many U.S. corporations elect to use a fiscal year end instead of a calendar year end for federal income tax reporting purposes. Due to a provision in the recently enacted Tax Cuts
See MoreUS: IRS publishes annual advance pricing agreement report for 2017
On 30 March 2018 with an announcement, IRS published Advance Pricing Agreement (APA) report for the calendar year 2017. The report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide
See MoreUS: IRS publishes a notice concerning CbC reporting requirements of certain U.S. MNE groups
On 30 March 2018, IRS released an advance copy of Notice 2018-31 concerning national security considerations with respect to country-by-country (CbC) reporting. In consideration of the national security interests of the United States, the notice
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
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
See MoreUnited States: ADD/CVD Roundup for March 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
See MorePGA Highlights: March 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
See MoreUS: IRS publishes interest rate for the second quarter of 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%
See MorePGA Highlights: February 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
See MoreUnited States: ADD/CVD Roundup for February 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
See MoreUS: IRS files pre-trial memorandum against Coca Cola in transfer pricing dispute
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
See MoreUS: IRS increases the fees for advance pricing agreements
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:
See MoreUnited States: ADD/CVD Roundup for January 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
See MoreUS: President signs Tax Cuts and Jobs Act
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
See MorePGA Highlights: January 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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