Archives: 2015

• Financial Services Companies Seek Exceptions to 367(d) Rules

  by Dolores W. Gregory (Bloomberg)

  Major financial institutions and trade groups, in a series of comments to the Internal Revenue Service, lodged a plea for an industry exception to proposed regulations that would impose tax on the outbound transfer of foreign goodwill and going concern value.
  For the DTR story, go here. (subscription required)

  By Gregory, Dolores W. , posted on Monday January 4, 2016

• U.S. Considers National Security Exception to Reporting Rules

  by Dolores W. Gregory (Bloomberg)

  The Internal Revenue Service's proposed rules on country-by-country reporting contain few surprises, practitioners say, but raise several questions—including an unexpected one about whether the new requirements should include an exception for national security reasons.
  
  
  For the DTR story, go here. (subscription required)

  By Gregory, Dolores W. , posted on Thursday December 24, 2015

• IRS issues proposed regulations on country-by-country reporting

  by PwC

  On December 21, 2015, the Treasury Department and the IRS issued highly anticipated proposed regulations [REG-109822-15] that would require annual U.S. country-by-country (CbC) reporting for U.S.-parented multinational enterprise (MNE) groups. In issuing the regulations, the Treasury Department has demonstrated its intent to meet the multilateral commitment it made in the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project negotiations to collect the CbC information for purposes of exchanging it with other governments.

  For the PwC Insight, go here.

  By PwC, posted on Monday January 4, 2016

• Brady Statement on Release of Treasury’s Country-by-Country Regulations

  by Committee on Ways and Means

  Congress will review new Treasury regs on country-by-country reporting in order to prevent the establishment of base erosion and profit-shifting policies that enable foreign governments to misuse information reporting and exploit U.S. companies, House Ways and Means Committee Chair Kevin Brady, R-Texas, said in a December 21 statement.
  For the statement, go here.

  By Committee on Ways and Means , posted on Tuesday December 22, 2015

• Proposed CbC Regs' Effective Dates May Create Problems

  by Ryan Finley (Tax Notes)

  Differences between the effective dates in the proposed country-by-country (CbC) reporting regulations(REG-109822-15) issued by Treasury and the IRS and those in the report on action 13 (transfer pricing documentation) of the OECD's base erosion and profit-shifting program may create timing mismatch problems, according to KPMG's Manal Corwin and Kimberly Tan Majure.

  For the TNT story, go here. (subscription required)

  By Finley, Ryan , posted on Wednesday December 23, 2015

• Preparing for a Tsunami of International Tax Disputes

  by Todd Welty, Mark P. Thomas, Laura L. Gavioli, and Cym H. Lowell (Tax Analysts)

  Todd Welty, Mark P. Thomas, Laura L. Gavioli, and Cym H. Lowell discuss the need to improve international tax dispute resolution processes in light of the predicted increase in worldwide tax disputes.
  For the WWTD article, go here. (subscription required)

  By Welty, Todd , Mark P. Thomas, Laura L. Gavioli, and Cym H. Lowell , posted on Wednesday December 23, 2015

• Brady Plans to Set Stage for a Broader Tax Overhaul

  by Kaustuv Basu and Stephen K. Cooper (Tax Notes)

  With tax extenders out of the way, Ways and Means Committee Chair Kevin Brady, R-Texas, wants to focus on international tax reform in 2016 and set the stage for a broader tax overhaul after the presidential election.
  Brady, who took over as committee chair in early November, told Tax Analysts in two exclusive conversations on December 17 and 18 that he has one-, two-, and four-year plans in mind when it comes to overhauling the tax code.
  For the TNT story, go here. (subscription required)

  By Basu, Kaustuv and Stephen K. Cooper, posted on Tuesday December 22, 2015

• Tax Group Seeks to Ease Burden for CFCs Supporting U.S. Debt

  by Alison Bennett (Bloomberg)

  The New York State Bar Association Tax Section urged the IRS to make it clear that multiple controlled foreign corporations that support a debt obligation of a U.S. person won't each be stuck with the entire obligation under tax code Section 956(d).
  
  For the DTr story, go here. (subscription required)

  By Bennett, Alison , posted on Wednesday December 23, 2015

• NYSBA: Don't Apply Foreign Partner Transfer Rules to All

  by Laura Davison (Bloomberg)

  The IRS should exclude partnerships that have limited opportunities for abuse from rules that will crack down on transferring appreciated assets to foreign partners to escape U.S. tax, the New York State Bar Association Tax Section said.
  
  For the DTR story, go here. (subscription required)

  By Davison, Laura , posted on Wednesday December 23, 2015

• Developing countries show strong interest in the OECD's BEPS recommendations

  by PwC

  Many developing countries may implement the recommendations of the BEPS project that are relevant to them. This list of countries and topics seems to be wider than many commentators expected. 

  The OECD's Task Force on Tax and Development meeting on 2-3 November 2015 allowed a number of countries to specify points of satisfaction or dissatisfaction with the BEPS recommendations. There were further, similar opportunities at recent regional BEPS meetings in various locations. The first plenary session of the Ad Hoc Group on the Multilateral Instrument and the 20th Global Forum on Tax Treaties also showed high levels of participation from developing countries.

  For the PwC Tax Policy Bulletin, go here.

  By PwC, posted on Wednesday December 23, 2015