US: IRS Releases Transfer Pricing Audit Roadmap
On 14 February 2014 a Transfer Pricing Audit Roadmap was issued by the Large Business and International (LB&I) division of the IRS. This sets out the procedures in relation to the conduct of a transfer pricing audit and the timeline to follow.
See MoreUS: BEPS to Compound Global Tax Risks
Enterprises are expecting that tax risks are likely to increase more in the coming years, according to a survey of tax and finance executives in twenty five countries by the advisory firm Ernst and Young. The survey looked at the views of companies
See MoreUS Taxpayers Not Sensitive To State Income Tax Rates
The US Center on Budget and Policy Priorities has put together a report indicating that people relocating within the US do not generally regard State taxation as an important driver in their decision. This is the case even though there can be
See MoreUS Businesses Urge Two-Year Renewal of Tax Extenders
In the US the Business Roundtable (BR) has written to the Senate in relation to certain tax issues. The BR is a business grouping of CEOs from large US companies who have USD 7.4 trillion in annual revenues and together make up more than a third of
See MoreTaiwan- FATCA Agreement Expected In June 2014
Taiwan is expecting to finalize a FATCA agreement with the US by end of June 2014. The FATCA Act requires the IRS to gain information about accounts of US citizens and residents with foreign financial institutions. To ensure that this can be done
See MoreSwiss Discuss Banking Sector Tax Disputes With The US
Recent discussions between the US and Switzerland have centered on a US tax dispute settlement program for category two, three, and four banks and the current US criminal investigations into category one banks that are domiciled in Switzerland. The
See MoreUS: New treaty delayed in Senate due to renewed opposition
Based on privacy concerns Senator is opposing the ratification of some US tax treaties including the Hungary – United States Income Tax Treaty (2010). The Senator is particularly concerned that the US government would be permitted by the treaty
See MoreUS – IRS to Restructure Services for Small Businesses
The IRS is considering a project to reorganize operations at its two largest business units, Wage and Investment (W&I) and Small-Business Self Employed (SB/SE). The aim would be to eliminate the duplication that may arise from the potential
See MoreUS: IRS eases enforcement for FATCA compliance for some taxpayers
In Notice 2014-33, the IRS has announced that it will treat calendar years 2014 and 2015 as a transition period for purposes of enforcing and administering implementation of the Foreign Account Tax Compliance Act (FATCA) by all withholding agents
See MoreSingapore- US: Reach FATCA Agreement
The US and Singapore have completed their negotiations in respect of an intergovernmental agreement (IGA) to allow institutions in Singapore to carry out the provisions of the Foreign Account Tax Compliance Act (FATCA). The FATCA requires the IRS to
See MorePakistan Warns Banks to Register For FATCA
The State Bank of Pakistan has issued advice to financial institutions to ensure that they register with the US IRS in respect of the Foreign Account Tax Compliance Act (FATCA). They have given this advice because the intergovernmental agreement
See MoreUS: Committee Selects US Tax Extenders to Make Permanent
The Chairman of the US Ways and Means Committee has conducted a hearing to determine which “tax extenders” that expired at the end of 2013 should be permanently extended. There were more than fifty tax breaks expiring at the end of 2013 and in
See MoreUS May Close Door on Russian FATCA IGA Talks
Talks with Russia on an intergovernmental agreement (IGA) in connection with the FATCA legislation have been suspended by the US. The aim of the agreement if reached would be to enable foreign financial institutions (FFIs) in Russia to comply with
See MoreUS CEOs United On Need for Tax Reform
An annual survey of the views of US Chief Executive Offices (CEOs) reveals that more than 80 percent of those asked are of the opinion that the international tax system must be restructured and around two thirds of those asked want a more
See MoreIsrael and US Reach FATCA Agreement
Israel and the US have agreed on the wording of an intergovernmental agreement (IGA) that will enable the provisions of the US Foreign Account Tax Compliance Act (FATCA) to be carried out in Israel. The FATCA takes effect from 1 July 2014 and from
See MoreUnited States: ADD/CVD Roundup for April 2014
Following table shows the Federal Register notices related to ADD/CVD cases for April 2014 in United States. Country Product Investigations Case Number Links Brazil Certain Frozen Warmwater Shrimp Initiation of Antidumping Duty
See MorePGA Highlights: April 2014
In United States, The following events have been taken place under the several PGA during the month of April 2014. Agencies Summary Link Federal Register Labeling of Pesticide Products and Devices for Export: This action will allow placement
See MoreUS: Notice 2014-32 announces amendments to recently finalized Section 367(b) regulations applying to certain cross-border triangular reorganizations
The US Treasury Department and US Internal Revenue Service have issued Notice 2014-32 revising the final regulations on certain cross-border triangular reorganizations. The Notice applies where the reorganization involves one or more foreign
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