US Treasury Secretary backs the OECD talks on Global Minimum Tax
On 5 April 2021 the US Treasury Secretary Janet Yellen announced that she is working with the G20 countries to reach an agreement on a global minimum corporate tax rate. This is a reference to US cooperation with the G20/OECD initiative to design a
See MoreUS: IRS releases announcement and report concerning APMAs program
On 23 March 2021, the US IRS released an advance version of Announcement 2021-6 regarding the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2020. This twenty-second report
See MoreUS: IRS publishes revised CFC practice unit guidelines
On 22 March 2021, the U.S. Internal Revenue Service has published a revised international practice unit on Receipt of Dividends or Interest from a Related CFC. This Unit was revised to include the extension of the IRC 954(c)(6) look through rule
See MoreIMF: Analysis of Fiscal Measures to Reduce US Emissions
An IMF blog of 10 March 2021 entitled A New Vision for the US Climate Agenda looks at fiscal actions that would help curb emissions. The US climate plan aims for US carbon neutrality by 2050, achieved by public funding for clean energy
See MoreUS: IRS publishes the interest rates on overpaid and underpaid tax for Q2 2021
On 2 March 2021, the Internal Revenue Service announced that interest rates for the calendar quarter beginning April 1, 2021. The rates are unchanged from the previous quarter. The rates are: 3% for overpayments (2% in the case of a
See MoreUS and Argentina sign CbC exchange arrangement
On 27 January 2021, US and Argentina have signed a competent authority agreement to exchange country-by-country reports. The purpose of the agreement is to increase international tax transparency and improve access of their respective tax
See MoreUS: IRS announces interest rates for overpaid and underpaid tax for 1st quarter of 2021
On 3 December 2020, the Internal Revenue Service announced that interest rates for overpaid and underpaid tax for 1st quarter of 2021 which are unchanged from the previous quarter. The rates will be: three (3) percent for overpayments (two (2)
See MoreUS: IRS publishes guidance on forgiven PPP loans
On 18 November 2020, the Internal Revenue Service (IRS) has published an advance version of Rev. Proc. 2020-51 that provides a safe harbor allowing a taxpayer to claim a deduction in the taxpayer’s tax year beginning or ending in 2020 (the 2020
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US and Mexico renew competent authority agreement on Maquiladoras
On 16 November 2020, the Internal Revenue Service (IRS) announced that IRS and Mexico’s Servicio de Administración Tributaria (“SAT”) have agreed to renew the Qualified Maquiladora Approach Agreement (“QMA”), a coordination
See MoreUS: IRS and Treasury issue final regulations on foreign tax credits
On 12 November 2020, the Internal Revenue Service and Treasury published in the Federal Register providing guidance related to the allocation and apportionment of deductions and foreign taxes, foreign tax re-determinations, foreign tax credit
See MoreUS and Singapore sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated page on CbC reporting jurisdiction status table. Accordingly, on 6 October 2020, U.S. and Singapore have entered into a CAA for the automatic exchange of CbC reports. Pursuant to the provisions of
See MoreU.S. and Germany sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated information on CbC reporting jurisdiction status table. Accordingly, on 14 August 2020, U.S. and Germany sign an agreement on exchange of Country-by-Country reports. Each Competent Authority intends
See MoreUS: IRS updates parameters for APA and MAP
On 28 October 2020, the US Internal Revenue Service (IRS) published that it is updating parameters that the Advance Pricing and Mutual Agreement program (APMA), a representative office of the U.S. competent authority, will follow in implementing
See MoreUS: Final Withholding Regulations on Transfer of Partnership Interest by Foreign Partner
On 7 October 2020, the IRS issued final regulations on the withholding rules for transfers of partnership interests by foreign transferors. A gain on the sale or disposition by a non-US partner of an interest in a partnership that engaged in a
See MoreUS: IRS releases final regulations on interest expense deduction limitation
On 14 September 2020, the US IRS published the final regulations for the business interest expense deduction limitation published in the Federal Register. The final regulations vary slightly from the document released on IRS.gov on July 28,
See MoreUS: IRS announces tax relief for tropical storm ‘Isaias’ victims in Puerto Rico
On 10 September 2020, the Internal Revenue Service (IRS) has announced tax relief for tropical storm ‘Isaias’ victims in Puerto Rico. IRS states that tax returns and makes tax payments for individual and business has been extended until 30
See MoreUS: IRS announces interest rates for overpaid and underpaid tax for Q4
On 3 September 2020, the Internal Revenue Service announced that interest rates will remain the same for the calendar quarter beginning October 1, 2020. The rates will be: 3% for overpayments (2% in the case of a corporation);0.5% for the
See MoreUS: IRS publishes additional guidance on base erosion and anti-abuse tax
On 1 September 2020, the Internal Revenue Service issued final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT). To limit profit-shifting, the Tax Cuts and Jobs Act (TCJA) added a new tax, the BEAT. The
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