A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading
Banks in France have warned that they could be forced to close up to 40,000 accounts belonging to US citizens because of ongoing difficulties with the Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
The US IRS will once again examine allocations between group members of employee stock-based compensation in cost-sharing arrangements for transfer pricing purposes. ... - Continue reading
On July 3, 2019, the Seychelles Government announced that it has signed an intergovernmental agreement (IGA) with the United States to implement the requirements of the US Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
Guidance on the final GILTI regulations ... - Continue reading
Transfer pricing positions to be reviewed by IRS ... - Continue reading
It has been over a year since the Tax Cuts and Jobs Act (“TCJA”) was enacted. The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 (“the Section 482 regulations”) have remained relatively unchanged since 1986. Nonetheless, multinational corporations doing business within the United… – Continue reading
After years of deliberation and debate spanning two administrations, the Tax Information Exchange (United States of America) Bill, 2016, also known as the Foreign Account Taxpayer Compliance (FATCA) Bill was passed in the Senate on March 7, 2017. This following its unanimous passage in the House of Representatives, two weeks… – Continue reading
Section 7609(f) of the tax code allows the Internal Revenue Service to use a “John Doe” summons when the target is unknown. It has been used successfully by the IRS against banks and other financial institutions to find offshore accounts. Now, a district court in the Western District of Texas… – Continue reading
Congratulations are in order to Prince Harry and Meghan, Duchess of Sussex, as they welcomed their yet unnamed son into the world yesterday. The new little Earl (he won’t get a Prince title like his cousins) weighed in at a healthy weighs 7lbs. 3oz and comes with a life long… – Continue reading
The Cayman Islands Department for International Tax Cooperation has updated the relevant dates for reporting under the Foreign Account Tax Compliance Act and the Common Reporting Standard. The reporting deadline for CRS and FATCA remains May 31. The department announced that the late filing of 2018 CRS and FATCA reporting… – Continue reading
Rep. Lloyd Doggett, D-Texas, a member of the House Ways and Means Committee, and Senator Sheldon Whitehouse, D-R.I., a member of the Senate Finance Committee, introduced a pair of bills aimed at stopping corporations from using offshore tax havens and outsourcing jobs to other countries. The first bill, the No… – Continue reading
CRA now transferring 600,000 banking records per year under controversial information sharing agreement The Canadian government has shared more than 1.6 million Canadian banking records with the U.S. Internal Revenue Service since the start of a controversial information-sharing agreement in 2014, CBC News has learned. In 2016 and again in… – Continue reading
The Internal Revenue Service and the Treasury Department issued final regulations spelling out how U.S.-based companies will have to pay repatriation taxes on offshore profits under Section 965 of the tax code. The IRS released proposed regulations on Section 965 in August, and the proposed rules went through a public… – Continue reading
The IRS has issued guidance on excess business loss limitations and net operating losses following changes post-reform. The Tax Cuts and Jobs Act modified existing tax law by limiting losses from all types of business for non-corporate taxpayers. An excess business loss is the amount by which the total deductions… – Continue reading
The Internal Revenue Service is giving foreign-based banks with U.S. operations some leeway when calculating a major new international tax aimed at preventing global companies from shifting profits abroad. Multinationals often transfer payments, such as interest or royalties, to their affiliates in low-tax jurisdictions to maximize deductions and minimize tax… – Continue reading
The United States Department of Justice has charged four people with crimes allegedly brought to light by the International Consortium of Investigative Journalism’s Panama Papers expose, according to a DOJ announcement published earlier this month. They are the first US criminal charges stemming from the ICIJ’s 2016 investigation, which reported… – Continue reading
The US Internal Revenue Service (IRS) has issued guidance on the voluntary disclosure regime now in force, following the termination of its offshore predecessor on 28 September 2018. The new rules are effective for all disclosures after that date. And the possible penalties have gone up quite significantly. One of… – Continue reading
In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year… – Continue reading
The tax law gave a last-minute windfall to commercial property owners such as President Donald Trump. But regulations proposed by the Internal Revenue Service could diminish the benefit. Under the proposals, the agency’s rules would penalize real estate investors when they make like-kind exchanges — a common practice used to… – Continue reading
The American Institute of CPAs made recommendations to the U.S. Department of Treasury and the Internal Revenue Service on Monday about the proposed rules regarding the deduction for qualified business income under section 199A of the Internal Revenue Code. The proposed guidance, issued Aug. 16, 2018, provides rules addressing how… – Continue reading
The Internal Revenue Service’s Bank Secrecy Act program, in which it is supposed to safeguard against money laundering, is having only a minimal impact on tax compliance, according to a new report. The report, from the Treasury Inspector General for Tax Administration, noted that the Currency and Foreign Transactions Reporting… – Continue reading
With Bitcoin and other cryptocurrencies making huge sums of money for those adept at timing the market, the U.S. Internal Revenue Service (IRS) is keen to make sure it receives its cut of the profits. However, a lawyer from Morgan Lewis & Bockius states that many users do not realise… – Continue reading
The Internal Revenue Service is considering relaxing the rules for companies to qualify for tax-free spinoffs — a shift that could benefit drugmakers and tech firms with promising early-stage products. The agency said Tuesday it’s looking into whether units should still be required to generate revenue before a spinoff from… – Continue reading
The federal tax-collecting authority should update its virtual assets guidance because the lack of clarity creates uncertainty for citizens, Capitol Hill lawmakers said in an open letter. The US House of Representatives has urged the Internal Revenue Service (IRS) to release a new, comprehensive version of its cryptocurrency guidance because… – Continue reading
One of the claims made by proponents of last year’s once-in-a-generation tax reform act was that it would limit the scope for taxpayers to cheat on their returns by lowering the complexity of the Tax Code — but so far, tax professionals seem pessimistic. “Tax reform failed to properly fund… – Continue reading
IN 2015, the ASEAN Economic Community (AEC) Blueprint 2025 was adopted as part of the ASEAN 2025: Forging Ahead Together plan. This collaboration charts the broad trajectories of ASEAN economic integration from 2016 to 2025. It aims to strengthen and reinforce by 2025 these five AEC characteristics: 1. A highly… – Continue reading
The Internal Revenue Service is making some adjustments to its Compliance Assurance Process, a program aimed at large corporate taxpayers that involves cooperating with the IRS before any audits. As part of the proposed changes, the IRS said Monday it will shift the start of the application period to Oct…. – Continue reading
The Internal Revenue Service said Wednesday it will provide a new format for transcripts of individual tax returns that will safeguard taxpayer data by redacting personally identifiable information from Form 1040 series returns. The new transcript format will replace the old format and will be the default format available through… – Continue reading
Last week, Medtronic Plc suffered a legal setback in its bid to avoid a $1.4 billion U.S. tax bill — a ruling that may have costly implications for other multinationals battling the Internal Revenue Service over the use of overseas payments to lower their taxes. Companies including Facebook Inc. and… – Continue reading
Hedge Funds Are Struggling to Correctly Tax Crypto Holdings Amidst Unclear Regulations According to US law, bitcoin and other cryptocurrencies are taxed like property – similar to real estate. Amidst unclear regulations, however, hedge funds are struggling to correctly pay their taxes, which is a problem because the IRS just… – Continue reading
Long-awaited and highly anticipated proposed regulations for Code Section 199A, the new 20 percent deduction on “qualified business income” of pass-through entities, were released August 8 by the Treasury Department and the Internal Revenue Service, and experts are saying they’re broadly taxpayer-friendly. “The government did a good job of responding… – Continue reading
U.S. companies that had been unsure of how to calculate a new tax on profits they’ve stashed offshore now have official answers. The Internal Revenue Service issued proposed regulations on Wednesday on Section 965, governing the so-called repatriation tax, detailing which corporate taxpayers are subject to the tax, which assets… – Continue reading
(CNS): Financial Services Minister Tara Rivers was in Washington, DC, last week, trying to persuade US Senators and others that Cayman’s financial services industry is well regulated and adhering to tax transparency standards. Picking up from an earlier visit, the minister spoke with American lawmakers about the industry here and… – Continue reading
Revamped rules for Delaware Companies create new reporting obligations for owners and eliminate any vestiges of confidentiality that once made these offshore structures attractive for many property buyers. Effective since the beginning of 2017, Delaware Limited Liability Companies (LLCs) that are wholly owned by a non-resident, now become subject to… – Continue reading
A new agreement on international tax and financial information exchange aims to provide less opportunity to shelter wealth from taxation. Global wealth managers and advisors need to make sure they and their clients are in compliance. CHARLOTTE, N.C. (PRWEB) JULY 18, 2018 The Common Reporting Standard (CRS) for the automatic… – Continue reading
The Internal Revenue Service and the Treasury Department issued a notice Friday saying they intend to issue regulations around estates and non-grantor trusts, which may affect one tactic that some wealthy taxpayers have been using to get around the cap on deducting local property taxes under the new tax law…. – Continue reading
The Internal Revenue Service spent nearly $380 million to implement the Foreign Account Tax Compliance Act, but so far isn’t prepared to enforce the law, according to a new report. The report, from the Treasury Inspector General for Tax Administration, examined the IRS’s efforts to implement FATCA, which was included… – Continue reading
The Mauritius Revenue Authority on June 11, 2018, warned those financial institutions required to report information on the accounts of US persons under the US Financial Account Tax Compliance Act that declarations are required by Jule 31, 2018. The statement said: “FATCA information in respect of the year 2017 will… – Continue reading
The Foreign Account Tax Compliance Act (Fatca) is a US legislation that is part of the 2010 Hiring Incentives to Restore Employment (HIRE) Act, and forming part of four new sections incorporated into the US Internal Revenue Code. It is a law designed to improve offshore US tax collection by… – Continue reading
In recent months, Facebook CEO Mark Zuckerberg has been hauled before lawmakers in the United States and the European Union to respond to criticism of the company’s privacy policies and sharing of user data. Now the company’s dodgy tax practices are facing increased scrutiny from an even more important source:… – Continue reading
The Australian federal government has proposed a tax on digital advertising that could raise up to $200 million each year but could have serious consequences for corporate Australia. Scott Morrison, Australia treasurer, mentioned in his budget speech that the $7 billion in sales from Australians to United States owned media… – Continue reading
Defying a warning from the Internal Revenue Service, the Illinois Senate has overwhelmingly approved a bill intended to give local taxpayers a workaround for new federal caps on state and local tax deductions. […] The Senate action came yesterday afternoon when, by a 51-1 margin with one abstention, the Senate… – Continue reading
The Internal Revenue Service has issued a new template that corporate taxpayers need to use when asking for an advance pricing agreement with the IRS. Advance pricing agreements are prior agreements between multinational companies and the IRS on the appropriate transfer pricing method to use for a given set of… – Continue reading
The United Kingdom’s parliament has enacted a new law requiring its overseas territories — which include notorious tax havens like Bermuda, the Cayman Islands, and the British Virgin Islands — to start disclosing by 2020 the owners of corporations they register. This could shut down a huge amount of offshore… – Continue reading
Ferreting out people who want to hide their assets and income overseas is nothing new for the Internal Revenue Service. And for roughly nine years, the agency has sponsored programs tailored to those taxpayers who were prepared to come forward and disclose their unreported foreign assets and income in exchange… – Continue reading
Legislation led by U.S. Rep. Peter Roskam (R-IL) to reform Internal Revenue Service (IRS) civil asset forfeiture tools and his other priorities to protect taxpayers cleared the U.S. House last week as part of a larger IRS modernization initiative. The House on April 18 passed the Taxpayer First Act, H.R…. – Continue reading
Officials say fraudulent claims fell off quickly after new technologies took the state off attackers’ easy-target list. With tax season comes attempted fraud, as crooks use false identities to try to trick all levels of government into sending them refund checks. There are ways to fight back, though, and Indiana… – Continue reading
The rich are getting richer in America but that prosperity is not trickling down the economic food chain, with investment capital pooling up in thriving portions of big cities. One reason for this, experts believe, is the amount of wealth tied up in assets—real estate holdings and stock portfolios, primarily—that… – Continue reading
US taxpayers who have failed to declare their offshore money will lose the chance to confess to the Internal Revenue Service later this year. The IRS has announced that the Overseas Voluntary Disclosure Program will close on September 28. In the 10 years the OVDP has run, 56,000 taxpayers have… – Continue reading
