Tag Archives: Action 13

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

▪ Written 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

International Tax Advisory: IRS Floats Updated Qualified Intermediary Agreement

▪ Written 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.

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

▪ Written 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.