Category: Internal Revenue Service (IRS)

Tax Rule Aimed at Corporate ‘Earnings Stripping’ Under Review

Obama-administration regulation drew criticism as overbroad Trump ordered review of tax rules that may pose undue burdens A federal rule aimed at limiting corporate “earnings stripping’’ for tax-avoidance purposes may pose an undue burden on taxpayers and may be changed or rescinded, according to a U.S. Internal Revenue Service notice....

IRS opens Country-by-Country Reporting site online

The Internal Revenue Service has created a new section on its IRS.gov website dedicated to information on the Country-by-Country Reporting rules of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting project, which aims to discourage tax avoidance by multinational companies. The new Country-by-Country Reporting web pages...

Lawyers as “Gate Keepers” – The European Parliament Examines the Roles of Attorneys in Tax Evasion and Laundering Schemes

Starting on April 27, and finishing on May 2, the European Parliament (EP)’s Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is holding two meetings to present several related studies which address the impact of, and the fight against, tax evasion and money laundering, particularly in...

China’s New Transfer Pricing Rules Keep Arm’s-Length Approach

China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the...

Law Society reaches understanding with IRD on FATCA

The New Zealand Law Society says that following discussions with Inland Revenue and the New Zealand Bankers’ Association it has now reached an understanding with Inland Revenue about application of FATCA to lawyers’ trusts accounts. FATCA is the United States’ Foreign Account Tax Compliance Act. Its objective is to reduce...

EU Lawmakers Visit IRS, Delaware as Tax Haven Concerns Mount

The European Parliament’s Panama Papers investigative committee is preparing for a “fact-finding” visit with counterparts in the U.S. Congress, as well as officials from the Treasury Department and Internal Revenue Service. The European Union lawmakers’ four-day U.S. trip, which begins March 21, will include a visit to Delaware for meetings...

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue 2

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number...

3 Key Tax Rules Governing Typical Business Deductions

What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,...

Companies Get Draft Instructions for U.S. Global Tax Reports

U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that...

IRS warns of ‘Dirty Dozen’ tax scams

MARTINSBURG — The Internal Revenue Service has started releasing this year’s top 12 scams targeting consumers known as “The Dirty Dozen.” The annually compiled list features a variety of scams the agency says are common and that taxpayers could encounter anytime, but especially during peak filing season. Phishing schemes lead...

Parliament passes FATCA

The Foreign Account Tax Compliance Act (FATCA) United States of America Implementation and Enforcement of the Inter-Governmental Agreement was passed in Parliament without opposition, making it mandatory for Antigua & Barbuda’s banks to provide the banking information of US citizens to the Internal Revenue Service (IRS). The Act requires local...

Many tax-exempt charities don’t meet IRS requirements

Even though the Internal Revenue Service approves 94 percent of the applications it receives from charities for tax-exempt status filed through the simplified Form 1023-EZ, approximately a quarter of them do not meet the IRS’s own requirements. A recent report by the National Taxpayer Advocate pointed out that Treasury Department...

Deloitte licensed to provide FATCA services in Kuwait

The Kuwait Ministry of Finance (MOF) has issued a ministerial resolution announcing that Deloitte & Touche, Al-Wazzan & Co in Kuwait has been certified with the ministry for the provision of Foreign Account Tax Compliance (FATCA) services. FATCA is a US legislation which aims to combat tax evasion by US...

GAO-17-103, International Taxation: Information on the Potential Impact on IRS and U.S. Multinationals of Revised International Guidance on Transfer Pricing, January 27, 2017

What GAO Found In 2015, the Organization for Economic Co-Operation and Development (OECD) issued revised guidelines, including 15 actions to help reduce base erosion and profit shifting (BEPS) of multinational enterprises (MNEs). One action focuses on transfer pricing guidance with the intent of aligning MNE profits with the location of...

Israel and U.S. Begin Sharing Data in Crackdown on Tax Evasion

The Israel Tax Authority says Americans have provided information on 35,000 accounts held by Israelis in the U.S. and on an unspecified number of American accounts in Israel. The Israel Tax Authority said Monday it had begun passing on data on Israeli bank accounts held by American citizens and Green...

Cayman Islands: Cayman Islands AEOI Update – Second Tranche of CRS Regulations Released

The Cayman Islands Government issued the second tranche of the Common Reporting Standard (“CRS”) regulations at the end of December 2016. Updated Guidance Notes will be issued in Q1 2017 by the Cayman Islands Tax Information Authority (“TIA”) to assist with the implementation of the regulations. Furthermore, TIA stated in...

UK opposes planned US dividend tax for offshore investors

The US government is facing calls to delay the introduction of a new tax on foreign investors in US equity-linked derivative transactions, after the G5 group of countries signalled their opposition and the US Securities Industry and Financial Markets Association (SIFMA) indicated its members would not be ready for the...

US AND GRENADA FATCA AGREEMENT GOES INTO EFFECT

The Governments of the United States and Grenada have signed the Foreign Account Tax Compliance Act (FATCA) that will enforce a requirement for US citizens to file yearly reports on their non-US financial accounts. “This allows us to work together to ensure that financial institutions here in Grenada can help...

Microsoft agrees to more transparency on taxes in Australia

The Australian government is one of the most aggressive in highlighting the issue of multinational corporations avoiding taxes through extensive use of tax havens. Microsoft’s Australian subsidiary will start disclosing the amount of tax it pays in Australia, opting in to a government-transparency program aimed at shedding light on the...

Dumping Obama’s faux foreign tax legislation should be high on Trump’s to-do list

President-elect Donald J. Trump has stated that among his top priorities will be revocation of President Barack Obama’s misguided executive orders. Among the first such items to get the ax should be a series of legally infirm international agreements to implement a monstrosity unfamiliar to most Americans, called the Foreign...

Ukraine’s Cabinet of Ministers endorses draft agreement on FATCA with US

Ukraine’s Cabinet of Ministers has approved a draft agreement with the U.S. government to improve the implementation of tax rules and apply the provisions of the U.S. foreign account tax compliance act (FATCA). The decision is outlined in government resolution No. 821-r dated November 9, 2016 posted on the government’s...

IRS Nets $10 Billion FATCA Tax Haul

The US Internal Revenue Service (IRS) has netted more than $10 billion in secret offshore cash and investments. The controversial Foreign Account Tax Compliance Act (FATCA) has encouraged more than 100,000 taxpayers to reveal their overseas holdings. But the IRS suggests this is just the start as FATCA cranks up...

Cambodia on alert for US taxpayers

With the Internal Revenue Service (IRS), the tax-collection arm of the United States government, stepping up its global sweep to catch American individuals and corporations hiding their overseas earnings, the American Chamber of Commerce in Cambodia yesterday held a presentation for investors and financial institutions to make sure they are...

IRS Offshore Voluntary Compliance Tops $10 Billion

As international compliance efforts pass several new milestones, the Internal Revenue Service reminds U.S. taxpayers with undisclosed offshore accounts that they should use existing paths to come into full compliance with their federal tax obligations. Updated data shows 55,800 taxpayers have come into the Offshore Voluntary Disclosure Program (OVDP) to...

China Issues More Rigorous Advance Pricing Agreement Rules

China is requiring multinational groups to provide more information, including the location-specific advantages of their Chinese entities, when they apply for advance pricing agreements. The State Administration of Taxation’s Public Notice 64, dated Oct. 11 and released Oct. 18, requires companies to provide the additional information to Chinese tax authorities...

IRS, Mexico Reach Tax Deal For Contract Manufacturers

U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración...

US gives Trinidad new deadline for approving FATCA legislation

The United States is recommending that Trinidad and Tobago pass the Foreign Account Tax Compliance ACT (FATCA) by February next year, providing a five-month breathing space for the country. US Ambassador John Estrada in a brief statement issued from Washington said he wanted to provide an update on FATCA after...

Government, Opposition to meet on FACTA legislation

PORT OF SPAIN, Trinidad, Sept 10, CMC – Government and opposition legislators are to meet here on Monday as the deadline for meeting the September 30 deadline for passing the Foreign Account Tax Compliance ACT (FATCA). Caribbean financial executives have in the past bemoaned what they deem as an uneven...

Israeli government enjoined from disclosing personal account information to the IRS

One disadvantage of United States citizenship is that all income from whatever source, worldwide, is subject to taxation. This is true regardless of how one obtains American citizenship; indeed, there are many “accidental Americans” who, by dint of having been born to a person with American citizenship, are technically American...

How Amazon Values Its Tech Assets for Tax Purposes

Regulators in Europe and the US say that the value Amazon places on the technology behind user experience varies radically depending on which appraisal will lower its tax bill. Jeff Bezos’s relentless focus on user experience has helped him make Amazon the most valuable e-commerce company in the world. But...

IRS to Allow Voluntary Reporting of Global Tax, Profit

An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the...

«Delaware» Crackdown: All Bark and No Bite?

The U.S. has used judicial might to successfully pursue offshore tax cheats all over the world. A little-noticed new rule introduced by Barack Obama’s administration gets tough on U.S. states such as Delaware and Nevada, which are notorious for murky shelters often used for illicit purposes. But there is a...

ABA Pushes IRS On Taxation Of Cloud Transactions

The Section of Taxation of the American Bar Association (ABA) has written to the US Internal Revenue Service (IRS) saying that there is a pressing need for guidance from tax authorities due to the rapid growth of the cloud industry. The ABA noted that, although the Organisation for Economic Co-operation...

Undeclared incomes: Tax info-sharing agreements is a step in the right direction

Almost every country and every government now is fighting to detect undeclared Incomes and boost their tax collection. This could potentially help various countries show and collect large taxes from offshore accounts. The renewed thrust on automatic exchange of information (AEOI) between countries could achieve what seemed like a dream...