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Searching Content indexed under Tax Authorities by David E. Sites ordered by Published Date Descending.
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1
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
2
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
3
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
4
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
5
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
6
Tax Court Deals IRS Another Transfer Pricing Loss
On March 23, in Amazon.com, 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
7
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
8
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
9
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
10
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
11
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
12
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
13
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
14
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
15
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
16
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
17
Treasury Finalizes And Significantly Modifies Debt-Equity Regulations Under Section 385
New final and temporary regulations under Section 385, addressing the treatment of related-party debt, significantly narrow parts of the controversial proposed regulations released in April.
United States
9 Nov 2016
18
Officials Provide Update On International Guidance Projects
On Sept. 30, officials from Treasury and the IRS provided an update on a number of guidance projects relating to international tax.
United States
18 Oct 2016
19
U.S. Chamber Of Commerce Challenges Inversion Regulations
In a complaint filed on Aug 4 in the Western District of Texas the US Chamber of Commerce and the Texas Association of Business filed suit against the IRS and Treasury over the inversion regulations.
United States
22 Aug 2016
20
Ninth Circuit Holds Online Gambling Accounts Not Subject To FBAR Reporting
The Ninth Circuit Court of Appeals held on July 26 that a taxpayer was not required to report certain online gambling accounts to the IRS...
United States
22 Aug 2016
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