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Action 13

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

March 15, 2017 By Matthew Moseley and Henry Birnkrant

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

Filed Under: International Tax Advisory Tagged With: Action 13, BEPS, CbC, Chapter V, country-by-country reports, form 8975, IRS, MNE, multinational enterprise, OECD, Organisation for Economic Co-operation and Development, Reg. § 1.6038-4, Rev. Proc. 2017-23, Revenue Procedure 2017-23, Schedule A, TD 9773

International Tax Advisory: IRS Floats Updated Qualified Intermediary Agreement

July 15, 2016 By Edward Tanenbaum and Heather Ripley

Our International Tax Group discusses the IRS’s proposed update to the qualified intermediary agreement set to expire this year.

Click here to read the full advisory.

Filed Under: International Tax Advisory Tagged With: Action 13, FATCA, FFIs, Foreign Account Tax Compliance Act, foreign financial institutions, Form W-8, Form W-8IMY, IGA, intergovernmental agreement, IRS, limited branch, limited FFI, Notice 2010-46, Notice 2015-66, Notice 2016-42, OECD, Organisation for Economic Co-operation and Development, QDD, QI, QSL, qualified derivatives dealers, qualified intermediary agreement, qualified securities lender, Rev. Proc. 2000-12, Rev. Proc. 2014-39, Rev. Proc. 2014-47, Section 3406, Section 871(m), The 2014 QI Agreement, withholding tax

International Tax Advisory: Taking a Gap Year: Delayed U.S. CbC Reporting Creates Hassle for U.S. Multinationals

June 15, 2016 By Edward Tanenbaum and Heather Ripley

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.

Click here to read the full advisory.

Filed Under: International Tax Advisory Tagged With: Action 13, BEPS, CbC, Country by Country Report, IRS, OECD, Organization of Economic Co-operation and Development, Treasury

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