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BEPS

Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System

October 15, 2021 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. Pillar One: a new taxing right in the digital worldPillar Two: a global minimum tax rate of 15%The road(blocks) ahead Read the full advisory here. [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: base erosion, base erosion and profit shifting, BEPS, Corporate tax rate, digitalization, Income Inclusion Rule, international, MLC, MNE, MNEs, OECD, Rome, Subject to Tax Rule, transfer pricing, Undertaxed Payment Rule, Washington D.C.

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

July 14, 2017 By Edward Tanenbaum and Stefanie Kavanagh

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

Filed Under: International Tax Advisory Tagged With: Action 14 initiative, Action 15, base erosion and profit shifting, BEPS, cross border tax disputes, Department of State, Department of Treasury, international tax, limitations on benefits, mandatory binding arbitration, MLI, model tax treaty provision, multilateral instrument, OECD, PPT, principal purpose test, Senate, Treasury Department

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: 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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