Searching Content indexed under Tax by David E. Sites ordered by Published Date Descending.
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Tax Court Holds That IRS's Cancellation Of Apas Was Abuse Of Discretion
An APA is an agreement between the IRS and a taxpayer on a transfer pricing methodology.
United States
23 Aug 2017
Tax Court Ruling On Redemption Of Partnership Interest By Foreign Partner May Allow For Refund Opportunity
On July 13, 2017, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 (2017), the U.S. Tax Court held that certain gain recognized by a nonresident partner...
United States
22 Aug 2017
Treasury Delays Documentation Requirements, Hints At More Regulation Changes
The Treasury Department has delayed for one year the effective date of the documentation requirements under the Section 385 regulations...
United States
17 Aug 2017
Rejecting A Revenue Ruling, Tax Court Rules That Foreign Partner Is Not Subject To U.S. Tax On Redemption Of Partnership Interest
On July 13, 2017, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3 (2017), the U.S. Tax Court held that gain recognized by a nonresident partner...
United States
16 Aug 2017
Treasury Identifies Eight Regulations Subject To Modification And Potential Repeal
The Treasury Department on July 7 issued Notice 2017-38 which identifies eight regulations — including those issued under Section 385 — that could be subject to some reform, including modification...
United States
21 Jul 2017
United States
6 Jul 2017
IRS Appeals Medtronic Transfer Pricing Loss To Eighth Circuit
The IRS has appealed its loss on in the Tax Court in Medtronic, Inc. v. Commissioner to the Eighth Circuit Court of Appeals.
United States
16 May 2017
Tax Court Deals IRS Another Transfer Pricing Loss
On March 23, in, Inc. & Subsidiaries v. Commissioner 148 T.C. No. 8 (2017) the Tax Court held that the IRS's approach to valuing an upfront cost sharing buy-in payment was arbitrary, capricious and unreasonable.
United States
20 Apr 2017
EU Council Reaches Agreement Expanding Hybrid Mismatch Rules
On Feb. 21, 2017, the Council of the European Union (EU Council) reached agreement on the terms of a draft that expanded Anti-Tax Avoidance Directive (ATAD 2).
European Union
28 Mar 2017
IRS Releases Draft Instructions For Country-By-Country Report
On Feb. 23, 2017, the IRS released draft instructions for Form 8975, "Country-by-Country Report" and Form 8975 (Schedule A), "Tax Jurisdiction and Constituent Entity Information."
United States
27 Mar 2017
Temporary And Final Rules Focus On Transfers Of Property By US Persons To Partnerships With Related Foreign Partners
The IRS and Treasury Department recently issued temporary regulations (T.D. 9814) and, by cross-reference, proposed regulations (REG-127203-15)...
United States
15 Feb 2017
Government Issues Temporary And Final Inversion Regulations
The IRS and Treasury recently released final and temporary regulations (TD 9812) under Section 7874.
United States
14 Feb 2017
IRS Provides Guidance On Early Adoption Of CbC Reporting
The IRS issued final regulations (TD 9773) on June 29, 2016, that will require U.S. multinationals with more than $850 million in revenue to report specific information on a CbC basis.
United States
14 Feb 2017
IRS Issues Final Regulations On PFICs
The IRS and Treasury published final regulations (T.D. 9806) that provide guidance on determining ownership of a passive foreign investment company (PFIC)...
United States
30 Jan 2017
IRS Issues Package Of FATCA Regulations
On Dec. 30, 2016, the government issued several final, temporary and proposed regulations related to information reporting and withholding obligations under the Foreign Account Tax Compliance Act (FATCA).
United States
30 Jan 2017
IRS Issues Regulations Limiting Creditability Of Foreign Income Taxes Following Covered Asset Acquisitions
On Dec. 6, 2016, the IRS and Treasury issued temporary (T.D. 9800) and proposed (REG-129128-14) regulations under Section 901(m).
United States
30 Jan 2017
Final Regulations Retroactively Affect Nonrecognition On Outbound Transfers Of Foreign Goodwill
The Treasury Department and the IRS recently issued final regulations relating to certain transfers of property by U.S. persons to foreign corporations (T.D. 9803).
United States
26 Jan 2017
IRS Issues Final Regulations On Information Reporting And Record Maintenance For Certain Disregarded Entities
The Department of the Treasury and the IRS recently released final regulations (T.D. 9796) that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation...
United States
26 Jan 2017
FinCEN Extends General Filing Deadline For FBARs, Continues Yearly Extension For Certain Individuals
The new annual due date for filing Form 114, Report of FBAR for foreign financial accounts is April 15 with a maximum extension for a six-month period ending on Oct. 15.
United States
24 Jan 2017
OECD Recommends Extension Of Time To Comply With Country-By-Country Notification Requirements
On Dec. 5, 2016, the Organisation for Economic Co-operation and Development (OECD) released guidance recommending that countries provide "flexibility" and "transitional relief"...
United States
20 Dec 2016
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