Hungary approves CbCR IGA with the US
Hungary’s parliament passed the 2024 Hungary-US Agreement on the Automatic Exchange of Country-By-Country (CbC) Reports on 4 November 2024. The CbC agreement was signed on 15 July 2024 by Hungary and on 1 August 2024 by the US. The newly
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US Representatives urge delay in reporting rules for beneficial ownership
US Representative Lisa McClain (R-MI) announced that she and 43 other Representatives sent a letter to Treasury Secretary Janet Yellen, on 5 November 2024, regarding beneficial ownership information, requesting a postponement in the implementation
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US: IRS finalises rules for disposing taxpayers’ seized property
The US Internal Revenue Service (IRS) issued the amended final regulations (TD 10011, RIN 1545-BQ34), on 4 November 2024,the document contains final regulations regarding the sale of a taxpayer’s property that the IRS seizes by levy. The final
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US elections: Tax policies to expect in a second term Trump presidency
Since the inception of his political career, Trump had championed the working middle-class, however, his biggest tax reliefs were reserved for corporations and the wealthy. As the US election concludes, it seems like a second term for Donald J Trump
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US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
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US: IRS clarifies CFC not eligible for dividends received deduction under section 245A
The US Internal Revenue Service (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides
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US and Taiwan to negotiate comprehensive tax deal to prevent double taxation
The US Department of the Treasury announced on 29 October 2024 that the US and Taiwan, under the auspices of the American Institute in Taiwan (AIT) and the Taipei Economic and Cultural Representative Office in the United States (TECRO), will begin
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US: IRS updates guidance on foreign-derived intangible income deduction
The US Internal Revenue Service (IRS) issued an updated practice unit titled, ‘IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII) on 24 October 2024. This revision eliminates references to unavailable resources and replaces the
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Liechtenstein, US to negotiate for tax treaty
Liechtenstein and the US delegation met on 22 October 2024 to discuss bilateral cooperation. Liechtenstein expressed interest in signing an income tax treaty with the US in the meeting. If an agreement is reached, it will be the first tax
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US: Congressional Research Service reviews mortgage interest deduction
The Congressional Research Service (CRS) released the In Focus report (IF 12789 ) at the US Library of Congress on 22 October 2024. This report analysed the mortgage interest deduction, highlighting policy options that Congress may
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US: Treasury publishes final rules on clean energy production tax credits
The US Treasury Department and the IRS published the final rules for the advanced manufacturing production tax credit under Internal Revenue Code (IRC) section 45X in the federal register on 28 October 2024. The final regulations ( RIN
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US, Taiwan to begin tax treaty negotiations
The US Department of the Treasury announced, on 29 October 2024, that the US and Taiwan, under the auspices of the American Institute in Taiwan (AIT) and the Taipei Economic and Cultural Representative Office in the United States (TECRO), will begin
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US: IRS extends temporary relief for foreign financial institutions required to report US TINs
The US Internal Revenue Service (IRS) issued Notice 2024-78 on 28 October 2024, in which it extended the temporary relief provided in Notice 2023-11, subject to the procedures and requirements of this notice, for certain foreign financial
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US: IRS announces 2025 tax inflation adjustments
The US Internal Revenue Service (IRS) released IR-2024-273 on 22 October 2024 about the annual inflation adjustments for tax year 2025. The Revenue Procedure 2024-40 provides detailed information on adjustments and changes to more than 60 tax
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US: IRS and Treasury release final rules for advanced manufacturing investment credit
The US Department of the Treasury and the Internal Revenue Service (IRS) announced in the IR-2024-275, on 22 October 2024, the final regulations that provide guidance regarding the implementation of the Advanced Manufacturing Investment Credit,
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US issues new rule for income tax withholding on foreign payees
The IRS and Treasury have published (RIN 1545-BN52, TD 10008) on 18 October 2024 outlining final regulations regarding income tax withholding on certain periodic payments and nonperiodic distributions from employer deferred compensation plans,
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US: Treasury, IRS relieves tax-exempt organisations from CAMT form filing for 2023 tax year
The US Department of Treasury and the Internal Revenue Service (IRS), in a release – IR-2024-277, granted a filing exception for tax-exempt organisations on 23 October 2024; they do not have to file Form 4626, Alternative Minimum Tax –
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US: Massachusetts plans limits on amnesty programme for non-filers
The Massachusetts Department of Revenue has issued a draft notice outlining potential restrictions on eligibility for certain taxpayers seeking to benefit from the Massachusetts Tax Amnesty Program 2024. The draft notice, “Working Draft TIR:
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