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 2024-40Â provides detailed information on adjustments and changes to more than 60 tax
See MoreUS: 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,
See MoreUS 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,
See MoreUS: 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 –
See MoreUS: 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:
See MoreUS: IRS introduces pass-through compliance unit in large business divisions
The US Internal Revenue Service (IRS) announced the new pass-through field operations unit announced last fall that has officially started work in its Large Business and International (LB&I) division to more efficiently conduct audits of
See MoreUS: FinCEN clarifies public utility exemption for reporting beneficial ownership
The US Treasury Department's Financial Crimes Enforcement Network (FinCEN)Â issued a final rule that clarifies the public utility exemption within the beneficial ownership information reporting rule. The final rule was published in the Federal
See MoreUS publishes updated Congressional Research Service report on SALT deduction
The US Congressional Research Service has released an updated report on the Federal Deductibility of State and Local Taxes on 16 October 2024. Under current law, taxpayers who itemise can deduct state and local real estate taxes, personal
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Chile: Treaty allows reduced withholding tax rates for US residents
According to Oficio No. 1763/2024, a payer in Chile may refrain from withholding tax, or withhold tax at a reduced rate, on income paid to a US resident entity under the Chile-US income tax treaty. This applies only after the US recipient submits
See MoreUS lawmakers urge Biden administration to address double taxation issues with Taiwan
Congressman Gerry Connolly (D-VA), a senior member of the House Committee on Foreign Affairs, co-Chair of the Congressional Taiwan Caucus, and the author of the Taiwan Tax Agreement Act of 2023, led four of his colleagues in writing to Secretary of
See MoreUS: IRS rules section 246(b) tax limit applies to GILTI, FDII income
The US Internal Revenue Service (IRS) Office of Chief Counsel (OCC) has released a memorandum (AM 2024-002) that examines how the taxable income limitation under the Internal Revenue Code (IRC) section 246(b) applies to both IRC section 951A global
See MoreUS: IRS to handle 400,000 employee retention credit claims
The US Internal Revenue Service (IRS) has issued the ERC claims update in a news release (IR-2024-263) on October 10, 2024, stating it is processing about 400,000 claims, representing approximately USD10 billion in eligible claims. Work on the
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US: Senator Wyden presses Pfizer to comply with pharma tax investigation
US Senate Finance Committee Chair Ron Wyden (D-OR), in a release, on 3 October 2024 announced that Pfizer is the sole company unwilling to cooperate with the Finance Committee's investigation into how major pharmaceutical firms utilise offshore tax
See MoreUS: IRS releases 2022 tax gap projections of USD 696 billion
The Internal Revenue Service in a news release (IR-2024-262) on 10 October 2024 announced the tax gap projections for tax year 2022, a detailed analysis showing the nation’s projected gross tax gap of USD 696 billion. This reflects the difference
See MoreUS: IRS grants six-month filing extension for Exempt Organisation Business Income Tax Return
The US Internal Revenue Service (IRS) has granted certain applicable entities that are making an elective payment election a six-month automatic extension of time to file an original or superseding Form 990-T, Exempt Organisation Business Income Tax
See MoreUS: IRS finalises rules for repatriating intangible property under Section 367(d)
The US Internal Revenue Service (IRS) and Treasury published the final regulations - Section 367(d) Rules for Certain Repatriations of Intangible Property in the Federal Register on 10 October 2024, which contains final additions and amendments to
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