US: IRS publishes draft form regarding the “base erosion and anti-abuse tax” (BEAT)
On 5 September 2018, the United States (US) Treasury and the Internal Revenue Service (IRS) released a draft of Form 8991 concerning the “base erosion and anti-abuse tax” (BEAT) reporting for 2018. In an effort to " level the playing field
See MoreUS: Appeal Court Overturns Altera decision on stock based compensation in CSAs
On 24 July 2018 the US Court of Appeals overturned the decision of the Tax Court in the case of Altera Corp, a case that concerned the inclusion of stock based compensation costs in cost sharing agreements (CSAs). The Appeal Court has determined
See MoreUS: Appeal Court Rules in Favour of IRS in Medtronic Case
On 16 August 2018 a US federal appeals court vacated and remanded a 2016 decision by the Tax Court in the case of Medtronic v. Commissioner. The Court of Appeals ruled that in its original decision in favour of Medtronic the Tax Court did not
See MoreUnited States: ADD/CVD Roundup for September 2018
Following table shows the Federal Register notices related to ADD/CVD cases for August 2018 in United States. Country Product Investigations Case Number Details Belgium Carbon and Alloy Steel Cut-To-Length Plate Initiation of Antidumping Duty
See MoreU.S. and Austria sign an agreement on the exchange of country-by-country reports
According to an IRS announcement on its website, the competent authorities of U.S. and Austria have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of country-by-country
See MorePGA Highlights: August 2018
In the United States the following events have taken place under the several PGA during the month of July 2018. Agencies Summary Federal Register Environmental Technologies Trade Advisory Committee (ETTAC) public meeting: This notice sets forth
See MoreUnited States: ADD/CVD Roundup for August 2018
Following table shows the Federal Register notices related to ADD/CVD cases for July 2018 in United States. Country Product Investigations Case Number Details Austria Carbon and Alloy Steel Cut-to-Length Plate Initiation of Antidumping Duty
See MoreU.S. and Croatia sign an agreement on the exchange of CbC reports
On 10 July 2018, the competent authorities of the U.S. and Croatia have concluded an arrangement on the exchange of country-by-country (CbC) reports. The competent authority arrangement (CAA) for exchange of country-by-country reports is on the
See MoreUS: 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.
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