US: Bankruptcy Court rejects IRS transfer pricing adjustment
The US Bankruptcy Court for the Middle District of North Carolina (Greensboro Division) has rejected an IRS transfer pricing adjustment because the taxpayer would incorrectly considered to be an independent distributor Re: Case No. 09-10846C-11G, 18
See MoreUS Approves Delay to EU Aviation ETS Implementation
A member of the relevant Senate Committee has welcomed the European parliament’s recommendation to extend to 2017 the moratorium on aviation emission taxes on international flights entering or leaving the EU. Various countries outside the EU have
See MoreUS Prepares To Enforce 45 FATCA Pacts
The US has announced that the agreements signed by foreign countries with the US in respect of the implementation of the FATCA legislation will be regarded as in effect until the end of 2014. The agreements are intended to ease compliance by
See MoreNew treaty between Hungary and US submitted to US Senate for ratification
The US Senate Foreign Relations Committee gave its approval to the new Hungary-United States double tax agreement (DTA) on 1 April 2014. This revised agreement is replace the existing Hungary-United States treaty when it enters into force. The
See MoreHong Kong signs tax information exchange agreement with the US
Hong Kong signed a tax information exchange agreement (TIEA) with the US on 25 March 2014. This agreement will strengthen the ability of the two jurisdictions to take action in respect of the enforcement of their taxes. Tax information exchange
See MoreUS – Luxembourg and US Sign FATCA Deal
An agreement has been concluded between Luxembourg and the US to ensure that institutions may carry out the provisions of the Foreign Account Tax Compliance Act (FATCA). The two countries reached the agreement on the basis of one of the model
See MoreUS – IRS Advises Taxpayers with Foreign Income
The IRS has issued instructions for /US citizens or residents who are living or working abroad, and for people in the US receiving foreign income in 2013. All income of US citizens or residents must be declared to the IRS and the rules in respect of
See MoreHong Kong and USA working for FATCA IGA
Hong Kong and the United States signed a tax information exchange agreement (TIEA) on March 25 2014. This will provide the legal framework within which an intergovernmental agreement (IGA) can be signed to enable the transfer of information in
See MoreUnited States: ADD/CVD Roundup for March 2014
Following table shows the Federal Register notices related to ADD/CVD cases for March 2014 in United States. Country Product Investigations Case Number Links Brazil Stainless Steel Bar Preliminary Results of Antidumping Duty Administrative
See MorePGA Highlights: March 2014
In United States, following events have been occurred under the several PGA during the month of March 2014. Agencies Summary Link CBP New Outlook CBP Website: The appearance of the U.S. Customs and Border Protection’s website has
See MoreUS – IRS Issues Revised Guidance on Business Expenses
The IRS has published a revised version of Publication 535 that gives guidance to taxpayers on claiming a tax deduction for business expenses. The publication contains instructions in respect of the years 2013 and 2014. This may be important for
See MoreUS – IRS Has Unclaimed 2010 Refunds For Almost 1m Taxpayers
The IRS has indicated that almost a million taxpayers are due tax refunds that have not yet been claimed, because they have not yet filed a federal tax return for 2010. As there is a three year deadline for such claims the returns must be filed by
See MoreSouth Korea and US Agree on Text Of FATCA Agreement
South Korea has announced that it has agreed to the regular exchange of information with the US from next year to assist the implementation of the Foreign Account Tax Compliance Act (FATCA). The FATCA legislation in the US aims to ensure that the US
See MoreUS – Supreme Court Agrees Severance Pay Is Taxable
In the US the Supreme Court has decided in favor of the IRS in a case involving the tax status of involuntary severance payments made to employees who have been laid off. The Court decided that these payments are subject to the provisions of the
See MoreUS – IRS Issues Virtual Currency Tax Guidance
The IRS has published guidance in respect of the use of Bitcoin and similar digital currencies. These are to be regarded for federal tax purposes as property rather than currency. This should remove uncertainty about the tax treatment of these
See MoreUS – IRS Extends Colorado Storm 2012 Tax Relief Deadline
The deadline for taxpayers in Colorado to make a decision on claiming disaster losses has been extended to 15 October 2014. The disaster relief relates to the severe storms and flooding that also gave rise to landslides in September 2013. Taxpayers
See MoreUS: IRS has released its annual report for 2013 on APAs
The annual report on the advance pricing and mutual agreement (APMA) program was issued by the IRS on 27 March 2014. The APMA program takes place as part of the work of the Large Business and International Division of the IRS. The report shows that
See MoreUS: Important information regarding intra-group services
The regulations of Treasury and IRS final intercompany service were issued on 31 July 2009. Some permitted transfer pricing methods for services are similar to the OECD methods but the services cost method and shared services arrangements are also
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