The U.S. Treasury and the Internal Revenue Service (IRS) have announced their Priority Guidance Plan for 2014–2015. This plan includes 41 separate projects concerning international issues. The international issues covered are transfer pricing, Subpart F income, inbound transactions, outbound transactions, foreign tax credits, sourcing and expense allocation, treaties, and other general topics.
U.S. Treasury and IRS Identify 2014-2015 International Tax Priorities
Posted by celliott on Sep 26, 2014 10:35:02 AM
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Topics: Tax Policy, Transfer Pricing, Foreign Tax Credits, International Tax, Priority Guidance Plan, Tax, U.S. Tax Treaties, Uncategorized
U.S. Tax Court Denies Amazon Summary Judgment in Transfer Pricing Case
Posted by celliott on Sep 22, 2014 11:30:54 AM
The U.S. Tax Court denied Amazon’s motion for a partial summary judgment related to a cost-sharing arrangement (CSA) under the transfer pricing provisions of the U.S. Internal Revenue Code. In Amazon.com, Inc. & Subsidiaries v. Commissioner of Internal Revenue, the court, finding a genuine dispute of material fact, held that Amazon must establish that costs are mixed before applying an allocation method to them.
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Topics: Amazon, Amazon.com Inc. & Subsidiaries v. Commissioner, International Tax, Tax, U.S. Tax Court, Uncategorized
U.S. Expats Launch Constitutional Challenge Against Canada Over FATCA
Posted by celliott on Sep 22, 2014 11:24:21 AM
A group representing American expatriates is taking legal action against the Canadian government for implementing the Foreign Account Tax Compliance Act (FATCA), a U.S. law designed to clamp down on tax evasion.
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Topics: Expats, FATCA, International Tax, Tax, Uncategorized
OECD Releases New Information Exchange Standard Intended to Thwart Tax Evasion
Posted by celliott on Sep 22, 2014 10:51:20 AM
The Organisation for Economic Cooperation and Development (OECD) released the full version of a new consolidated global Standard for Automatic Exchange of Financial Account Information in Tax Matters. It’s aimed at stopping tax evasion by helping governments around the world share information.
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Topics: OECD, International Tax, OECD Model Tax Convention, Tax, Tax Evasion, Uncategorized
In early June, the European Commission increased pressure on Ireland, the Netherlands and Luxembourg over their corporate tax practices, saying it would investigate deals they cut with Apple, Starbucks and Fiat. In fact it warned Ireland, which offers offshore tax status, that it could investigate more companies beyond Apple as part of its probe into taxes.
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Topics: Tax Law, EU, International Tax, Tax, Uncategorized
Taxpayers Don't Have to Report Virtual Currency on FBARs - Yet
Posted by celliott on Jul 24, 2014 11:14:41 AM
Bitcoin and other virtual currency are proving to have greater lasting power than many predicted when they first attracted broad public attention. They’re even beginning to attract the attention of taxing authorities.
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Topics: Bitcoin, FBAR, International Tax, Tax, Uncategorized
The IRS has released instructions for filing Form W-8BEN-E, “Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities).”
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Topics: FATCA, Form W-8BEN-E, International Tax, Tax, Uncategorized