US: final regulations on carryback of consolidated net operating losses
On 12 July 2023, the U.S. Treasury Department and IRS released final regulations in the federal register that affect corporations filing consolidated returns. These regulations permit consolidated groups that acquire new members that were members
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US: IRS issues practice unit on categorization of income and taxes into proper basket for FTC
On 15 May 2023, the U.S. IRS published a practice unit regarding Foreign Tax Credit - Categorization of Income and Taxes Into Proper Basket. This Practice Unit is revised to address changes from the implementation of the Tax Cuts and Jobs Act (TCJA)
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US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
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US: IRS issues guidance for the advanced manufacturing investment credit
On 14 June 2023, the Internal Revenue Service issued proposed regulations that provide guidance regarding the implementation of the elective payment provisions of the Advanced Manufacturing Investment Credit, established by the Creating Helpful
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US: Connecticut extends corporate surcharge under the budget bill 2024
On 12 June 2023, Connecticut Governor Ned Lamont of USA signed the budget bill (H.B. 6941) which includes an extension of the corporation business tax (CBT) surcharge for three years. The surcharge, set at a rate of 10%, applies to companies with
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US: IRS grants penalty relief for corporate alternative minimum tax
On 7 June 2023, the Department of Treasury and the Internal Revenue Service issued Notice 2023-42, which will grant penalty relief for corporations that did not pay estimated tax in connection with the new corporate alternative minimum tax
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US: IRS publishes interest rates remain the same for the third quarter of 2023
On 22 May 2023, the U.S Internal Revenue Service announced that interest rates for overpaid and underpaid tax for the calendar quarter beginning 1 July 2023, which will remain unchanged from the second quarter. For individuals, the rate for
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US: IRS releases interim guidance on review and acceptance of APA submissions
On 25 April 2023, the Internal Revenue Service (IRS) published a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect
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US: IRS issues interim guidance on review and acceptance of advance pricing agreement (APA) submissions
The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International
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US and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
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US: Tax proposals under the budget for fiscal year 2024
On 9 March 2023, U.S. President Joe Biden released the Fiscal Year 2024 Budget introducing following tax proposal. Ensures Corporations Pay Their Fair Share: The Budget includes an increase to the rate that corporations pay in taxes on their
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US: IRS extends the tax relief measures for taxpayers in disaster area
On 24 February 2023, the Internal Revenue Service announced that tax relief measures for disaster area taxpayers in California, Alabama and Georgia has been further extended to 16 October 2023. Previously, the deadline had been postponed to May 15
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US: IRS and Treasury issue final regulations on e-file for businesses
On 21 February 2023, the Department of the Treasury and the Internal Revenue Service issued final regulations T.D. 9972 amending the rules for filing returns and other documents electronically (e-file). These regulations will require certain filers
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US: IRS publishes interest rates on overpaid and underpaid tax for Q2 of 2023
On 13 February 2023, the Internal Revenue Service announced the interest rates for the calendar quarter beginning April 1, 2023. The rate will remain same as first quarter. Here is a complete list of the new rates: 7% for overpayments (payments
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Germany: Lower house of parliament adopts CbC exchange agreement with USA
On 9 February 2023, the German lower house of parliament (Bundestag) has approved a law to ratify the pending agreement with the USA on the exchange of CbC reports. The agreement was signed on 14 August 2020. The agreement will enter into force when
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US: Tax court approves agreement resolving APA cancellation case
On 3 February 2023, the US Tax Court issued a rule approving an agreement between Eaton Corporation and the IRS to adjust Eaton's tax bill for 2005 and 2006 to USD 8.8 million. The proposal stems from lengthy litigation in both the Tax Court and
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US: IRS invites to comments on CbC report form
As part of its continuing effort to reduce paperwork and respondent burden, on 5 January 2023, the Internal Revenue Service invited the general public and other federal agencies to take this opportunity to comment on proposed and/or continuing
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US businesses not obligated to report digital asset transactions until regulations are established
On 16 January 2024, the US Treasury Department and IRS declared that businesses in the US are not required to report transactions involving digital assets the same way as they must report the receipt of cash until the Treasury and IRS issue
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