At the 29th Annual Institute on Current Issues in International Taxation, held on December 15-16, IRS and Treasury officials discussed recently released regulations on outbound transfers of goodwill, pending EU State aid cases and other related subjects.
The officials discussed the final regulations released on December 12 address certain transfers of property, including foreign goodwill and going concern value, by United States persons to foreign corporations. These are described in section 367 of the Internal Revenue Code (Code). These regulations are effective on December 16, 2016.
Other subjects addressed were draft Form 8975 and Schedule A of Country-by-Country reporting, which were just published on the IRS website. “This is an early release draft of an IRS tax form, instructions, or publication, which the IRS is providing for your information as a courtesy,” the IRS informed.
They also informed about the United States’ intention to provide tax guidance on country-by-country reporting for multinationals that addresses reporting for LLCs in US groups and for tiered partnerships. Other subjects discussed included US tax treaty negotiations and the pending EU State aid cases involving tax rulings at the conference, as reported by the MNE Tax.
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