IRS: New International Practice Units Released
On February 19, 2016, the IRS released the following practice units: Outbound Transfer of Foreign Stock Followed by Check-The-Box Election; Residual Profit Split Method - Inbound; Revenue Procedure 99-32 Inbound Guidance; Interest Expense of a...
Posted by DRTP
On 22 February 2016
BEPS: Are CbC Surrogate a Reporting Trap?
Yes, according to Strategizing International Tax Best Practices (by Keith Brockman). In a recent blogpost, Mr. Brockman highlighted with respect to BEPS Country-by-country (CbC) reporting: "A review of CbC legislative actions by different countries reveals...
Posted by DRTP
On 11 February 2016
BEPS: US Treasury Proposes Changes to US International Tax Regime
The US Treasury Department has just released a series of proposals to modify the US international tax regime which includes: Restrict Deductions for Excessive Interest of Members of Financial Reporting Groups; Provide Tax Incentives for...
Posted by DRTP
On 10 February 2016
Canada: Automatic Exchange of Tax Information with Switzerland
Department of Finance announced today: "Canada intends to implement the CRS [Common Reporting Standard] starting on July 1, 2017, allowing a first exchange of information in 2018. As of the implementation date, Canadian financial institutions...
Posted by DRTP
On 5 February 2016
USA: State Aid? We Beg to Differ!
Presstv recently reported: "US blasts EU over ‘bias’ in tax probe of American firms The United States has denounced European Commission for its ‘unfair’ probe of American companies in EU’s tax investigations. Robert Stack, the...
Posted by DRTP
On 4 February 2016