US: IRS updates information regarding country-by-country (CbC) reporting
On 25 July 2018, Internal Revenue Service (IRS) updated the information concerning country-by-country (CbC) reporting in the United States. This includes an updated jurisdiction status table showing recently signed competent authority arrangements
See MoreUS: IRS issues new transfer pricing examination guide
On 29 June 2018, Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS released the Transfer Pricing Examination Process (TPEP) for use in transfer pricing examinations. Transfer Pricing
See MoreU.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MorePGA Highlights: July 2018
In the United States the following events have taken place under the several PGA during the month of June 2018. Agencies Summary Federal Register Correction in advance notification of sunset review: This notice serves to correct the July 2018
See MoreUnited States: ADD/CVD Roundup for July 2018
Following table shows the Federal Register notices related to ADD/CVD cases for June 2018 in United States. Country Product Investigations Case Number Details Argentina Lemon Juice Suspended Investigation A-822-804 See the Federal Register
See MoreUS: Central bank increases interest rates
On 13 June 2018, the Federal Reserve raised interest rates by 0.25% to new interest rates of 1.75% -2%. Two additional interest rises are expected by the end of 2018. Forecasts released after the US Federal Reserve's two-day meeting in Washington
See MoreUS: IRS publishes interest rate for the third quarter of 2018
On 8 June 2018, The Internal Revenue Service announced interest rate for the third quarter of 2018 that will remain as they were in the quarter that began on 1 April 2018. The rates that will begin from 1 July 2018 are as follows: 5 percent for
See MoreUnited States: ADD/CVD Roundup for June 2018
Following table shows the Federal Register notices related to ADD/CVD cases for May 2018 in United States. Country Product Investigations Case Number Details Austria Carbon and Alloy Steel Cut-To-Length Plate Antidumping Duty Order; Opportunity
See MorePGA Highlights: June 2018
In the United States the following events have taken place under the several PGA during the month of May 2018. Agencies Summary Federal Register Subsidy programs for softwood lumber and softwood lumber products: The Department of Commerce seeks
See MoreUS: IRS publishes new guideline for filing CbC reporting
On 18 May 2018, IRS released new guidance for filing the Form 8975 submitted by U.S. multinational enterprises (MNEs). When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975.
See MoreUS: IRS issues new advance pricing agreement (APA) template
On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).
See MoreUS and Indonesia sign MOU on the exchange of CbC reports
On April 26, 2018, the Internal Revenue Service issued a Memorandum of Understanding (MOU) between the Competent Authorities of the United States (US) and Indonesia, which includes an announcement of the temporary suspension of Indonesia's secondary
See MoreUnited States: ADD/CVD Roundup for April 2018
Following table shows the Federal Register notices related to ADD/CVD cases for April 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Antidumping Duty Orders A-357-820 See the Federal Register
See MorePGA Highlights: April 2018
In the United States the following events have taken place under the several PGA during the month of April 2018. Agencies Summary Federal Register Subsidy programs on cheese subject to an in-quota rate of duty: This notice provides Commerce's
See MoreUS: 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
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