President Trump is beginning to follow through on Candidate Trump’s promises to overhaul the tax code. Our International Tax Group examines the few details we have and the path any legislation must take to become law.
Unsurprisingly, the IRS got the same result by trying the same thing. Our International Tax Group analyzes the agency's latest effort to use a discounted cash flow analysis to audit a cost-sharing agreement.
The difference between #255 million and $3.6 billion
Using the comparable uncontrolled transaction method
Applying the 2011 cost-sharing regulations
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Ultimate parents of U.S. multinational enterprises now have instructions for Form 8975, the U.S. Country-by-Country Report. Our International Tax Group reviews what U.S. MNEs must do to comply with new U.S. filings requirements, as well as procedures for voluntary early filing intended to satisfy BEPS-related Organisation for Economic Co-operation and Development guidance in other jurisdictions.
Fixing the reporting mismatch
Revenue Procedure 2017-23
The form and instructions
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Our International Tax Group explores the final debt-equity regulations under Section 385, highlighting significant modifications to the rules proposed last April. While the regulations remain controversial, the final version brings a number of taxpayer-friendly changes, including a reduction in scope and general delay in application.
A recent Tax Court case shows the government’s willingness and ability to attack financing arrangements that do not reflect arm’s-length debt standards, even without the forthcoming Section 385 regulations. Our International Tax Group analyzes that case and reviews the IRS’s decision to stop treating some FATCA intergovernmental agreements as “in effect.”
Just a few key differences between U.S. proposed regulations on country-by-country reporting and the OECD’s BEPS recommendations are causing administrative headaches. Our International Tax Group minds the gap and explains what it means for U.S. multinationals.