Category Archives: International Tax Advisory

International Tax Reform Is Here

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Our International Tax Group reveals how savvy and flexible taxpayers can optimize their tax position in the new landscape created by the Tax Cuts and Jobs Act. New territorial system and mandatory repatriation Anti-base erosion measures Changes to Subpart F and other provisions Click here to read the full advisory. [...]Read more

Treasury Would Overhaul 2016 Regulatory Guidance

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With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and overhaul Sections 367 and 987. Revoking the Section 385 documentation rules Expanding the active business exception to foreign goodwill under Section 367 Deferring transition rules under Section 987 to 2019 Read the full advisory here. [...]Read more

Information Exchange Under the OECD’s Common Reporting Standard Begins Early in Select Countries

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At the end of the month, dozens of countries will begin exchanging information under the OECD’s Common Reporting Standard as “early adopters.” Our International Tax Group examines the CRS and its relation to FATCA. How does the CRS work? What are the reporting requirements? How will the CRS impact U.S. taxpayers? Read the full advisory here.  [...]Read more

International Tax ADVISORY: Big Tax Court Win for Eaton in Canceled APA Case

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The IRS abused its discretion when it canceled two advance pricing agreements. Our International Tax Group covers Eaton’s victory in the Tax Court and how it allays concerns about how worthwhile an APA can be. Public and judicial scrutiny Standard of review Where do we go from here? Read the full advisory here. [...]Read more

Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

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Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word. Repudiates decades-long position of IRS May have a real impact on U.S. foreign investment May not be the last word on the subject Read the full advisory here. [...]Read more

International Tax ADVISORY: Impact of the Multilateral Instrument of U.S. Taxpayers

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Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies. What is the multilateral instrument? Why didn’t the U.S. sign it? How will it impact U.S. multinationals? Read the complete advisory here. [...]Read more

International Tax ADVISORY – Trump’s Tax Reform Plan When the Dessert Pays for Dinner

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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.

  • The opening bid
  • Border tax
  • Path through the Senate

Read the full advisory here. 

International Tax ADVISORY: Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas

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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 Read the full advisory by clicking here. [...]Read more

International Tax ADVISORY – IRS Issues Draft Form and Instructions for Country-by-Country Reports

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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 Read the full International Tax Advisory here. [...]Read more

International Tax Advisory: The PFIC Regulations Get a Facelift

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Our International Tax Group discusses the new rules found in Treasury’s final regulations on passive foreign investment companies.

Read the full advisory by clicking here.