US: IRS increases the fees for advance pricing agreements
On 6 February 2018, the Internal Revenue Service (IRS) announced that fees for Advance Pricing Agreements (APAs) are expected to increase in a two-step process. For APA requests submitted after June 30, 2018, the fees will increase as follows:
See MoreUnited States: ADD/CVD Roundup for January 2018
Following table shows the Federal Register notices related to ADD/CVD cases for January 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Countervailing Duty Orders C-357-821 See the Federal Register
See MoreUS: President signs Tax Cuts and Jobs Act
Congress has passed the Tax Cuts and Jobs Act(the Act), and the President signed it on December 22, 2017. The most important changes in the area of corporate taxation are: Main corporate tax rate: Under the new Act, the corporate tax rate
See MorePGA Highlights: January 2018
In the United States the following events have taken place under the several PGA during the month of January 2018. Agencies Summary Federal Register Scheduling of upcoming public hearing: The Commission has scheduled a public hearing for March
See MoreUS: IRS issues guidance on penalties for understatement of income tax
On 29 January 2018, the US Internal Revenue Service (IRS) has issued the Revenue Procedure 2018-11 to recognize circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or position is adequate for the
See MoreIMF says tax reform of US boost global growth
On 22 January 2018, the International Monetary Fund revised upwards its forecast for global economic growth in 2018 and 2019, pointing out that US tax cuts would boost investment in the world's largest economy and help its major trading partners.
See MoreIndia: CBDT signed first bilateral APA with US
On 5 January 2018, the Indian Central Board of Direct Taxes (CBDT) signed the first bilateral advance pricing agreement (APA) with the United States. The CBDT has also indicated that there are many more bilateral APAs with the United States
See MoreUS: IRS releases directives on transfer pricing examinations
On 12 January 2018, the IRS Large Business and International (LB&I) division publicly released a set of five LB&I directives as guidance with respect for examinations of transfer pricing issues. Interim Instructions on Issuance of
See MoreUS: IRS updates information concerning country-by-country (CbC) reporting
On 18 January 2018, the IRS issued a release announcing updates and information regarding country-by-country (CbC) reporting requirements in the United States. Under the update list, IRS publishes new content on Country-by-Country (CbC) reporting
See MoreUS: Government signs joint statement on exchange of country-by-country tax reports with France
On January 12, the IRS announced on its website that the US and French competent authorities would like to sign a joint statement to spontaneously exchange CbC reports submitted by their respective taxpayers. The Competent Authorities desire to
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 19 January 2018, the Treasury Department and the Internal Revenue Service issued additional guidance (Notice 2018-13) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreUS: IRS issues guidance for computing the “transition tax” on foreign earnings
On 29 December 2017, the Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the “transition tax” under recent tax legislation enacted on Dec. 22, 2017. In general, newly-issued
See MoreUS: The Nation’s tax season will begin 29 January 2018
On January 4, 2018, the Internal Revenue Service announced that tax collection will begin on Monday, January 29, 2018, and taxpayers are reminded of certain tax credits that the refunds will not be available until the end of February. The IRS will
See MorePGA Highlights: December 2017
In the United States the following events have taken place under the several PGA during the month of December 2017. Agencies Summary Federal Register Notice of request for panel review: A request for panel review was filed on behalf of the
See MoreUnited States: ADD/CVD Roundup for December 2017
Following table shows the Federal Register notices related to ADD/CVD cases for December 2017 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Postponement of Final Determinations of Sales in Less Than
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
See More