News North America & Canada
US: Final and Proposed Regulations Regarding Foreign Tax Credits and Base Erosion and Anti-abuse Tax
; posted on
December 3rd, 2019
US Treasury and IRS have issued proposed and final regulations relating to Foreign Tax Credits (FTC) and the Base Erosion and Anti-abuse Tax (BEAT). These are significant international tax provisions of the Tax Cuts and Jobs Act (TCJA).
IRS Launches Proposed Rules Addressing Tax Consequences Of Discontinuation Of LIBOR And Other Interbank Offered Rates
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October 15th, 2019
The US Treasury Department and the US Internal Revenue Service (IRS) have issued proposed regulations REG-118784-18 to provide guidance on the tax consequences of the transition to the use of reference rates other than interbank offered rates (IBORs) in debt instruments and non-debt contracts (i.e.including interest rate swaps, cross-currency swaps and equity swaps).
Canada Opens Consultation on Tax Base Avoidance Measures To Strengthen Transfer Pricing Rule
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August 3rd, 2019
The Canadian Department of Finance has opened a consultation on proposed tax measures that would improve transfer pricing rules, counter tax base erosion via foreign affiliate dumping, and apply withholding tax to cross-border share lending arrangements.
Legislative proposals .
U.S. Releases Regulations on Dividends Received Deduction Limitation
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June 20th, 2019
Final temporary regulations from the U.S. IRS and Treasury on the Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception were published in the U.S. Federal Register. The regulations were published and are effective on 18 June 2019, and also serve as the text of proposed regulations published the same date.
US Issues Proposed Regulation On Ownership Attribution To Determine CFC Relatedness
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May 21st, 2019
The US Internal Revenue Service (IRS) released proposed regulations under section 954(d) of the Internal Revenue Code (IRC) on 17 May 2019, which were published in the federal register on 20 May 2019. The proposed regulations provide rules regarding the attribution of ownership of stock or other interests for purposes of determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under IRC section 954(d)(3).
U.S. Treasury Department Publishes List Of Boycott Countries That Result In Restriction Of Tax Benefits
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February 7th, 2019
The U.S. treasury department has issued the list of the countries that require cooperation with, or participation in, an international boycott as a condition of doing business.
Countries Lists .
IRS Issues Proposed Regulations On Base Erosion And Anti-Abuse Tax
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December 18th, 2018
The U.S. IRS issued the proposed regulations for the Base Erosion and Anti-Abuse Tax (BEAT) as introduced by the Tax Cuts and Jobs Act. Until the regulations are finalized, taxpayers may rely on the proposed regulations for taxable years beginning after 31 December 2017.
Canada Boosts Post US Tax Reform Competitiveness With Tax Measures
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November 22nd, 2018
In response to the U.S. Tax Cuts and Jobs Act, therefore on 21 November 2018, Canada has proposed three measures to boost its competitiveness, which would give it the lowest overall tax rate on new business investment among G-7 countries.
Objective .
IRS Announces Proposed Regulations On New Qualified Opportunity Zone Tax Incentive
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October 25th, 2018
The Treasury Department and the Internal Revenue Service (IRS) issued proposed regulations and other published guidance for the new Opportunity Zone tax incentive.
Qualified Opportunity Zone .
IRS Proposes Removal Of Final Regulations About Forth Minimum Documentation Requirements
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September 27th, 2018
The Internal Revenue Service (IRS) proposed to remove the final regulations which were published by the Treasury Department and the IRS under section 385 of the Internal Revenue Code (Code) on October 21, 2016.
Documentation Regulations Difficult to Implement .
US Released Proposed Regulations Under GULTI Regime Implementing International Tax Reform Changes
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September 18th, 2018
The US Department of Treasury and Internal Revenue Service (IRS) proposed new rules under the global intangible low-taxed income (GILTI) regulations, together with amendments under §951, 1502 and 6038 which would affect United States shareholders of controlled foreign corporations (CFC).
GILTI Regime .
United States: First Ever Conviction For Incompliance With FATCA
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September 13th, 2018
Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest, Hungary and Saint Vincent and the Grenadines, pleaded guilty to conspiring to defraud the United States by failing to comply with the Foreign Account Tax Compliance Act (FATCA).
FATCA .
US Proposes Regulations On New 20% Deduction on Passthrough Business
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August 9th, 2018
The US Internal Revenue Service (IRS) proposed regulations for a new provision allowing many owners of sole proprietorships, partnerships, trusts and S corporations to deduct 20 percent of their qualified business income.
Tax Cuts and Jobs Act .
US Clarifies Instructions For Country-By-Country Report Forms
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July 27th, 2018
The US Internal Revenue Service clarified several issues regarding Instructions for Schedule A (Form 8975), the country by country report file.
Fiscally Transparent Entities
IRS Replaces TP Roadmap With Transfer Pricing Examination Process
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July 10th, 2018
The Internal Revenue Service (IRS) in the US released the Transfer Pricing Examination Process (TPEP) to be uses in transfer pricing examinations. The TPEP, issued by the Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division, is a guide of best practices and processes to assist with the planning, execution and resolution of transfer pricing examinations consistent with the LB&I Examination Process.
US Supreme Court Decision on E-Commerce
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July 5th, 2018
The US Supreme Court decision on e-commerce concerns the possibility for states to apply sales taxes on e-commerce sales.
In 1992 this same court denied that possibility in the case - Quill Corporation vs.
US Tax Reform Blamed For Encouraging Avoidance And Creating Top 1 Haven
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June 19th, 2018
The fact that many big US companies enjoy a significantly lower tax rate than that in previous year makes US Tax Reform be blamed for encouraging such tax avoidance practice. The recent effect seems to deviate from dissuading US companies moving profits overseas, which is in part the initial goal of the Tax Cuts and Jobs Act (TCJA).
US Highlights Sharing Economy Tax For Small Business
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May 3rd, 2018
As from April 29 to May 5, 2018, the Inland Revenue Service (IRS) in the US holds the alleged National Small Business Week to coach small business owners and the self-employed on identifying their tax liability and enhancing tax compliance, considering there are new tax law changes enacted last December affecting them. Typically, the IRS highlights the sharing economy tax.
Canada Takes A Step Forward On Digital Economy Tax
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May 1st, 2018
The Canadian Standing Committee on International Trade recently published a policy report on E-commerce. The recommendations on taxing the online platform are getting considerable attention.
IRS Issues Guidance On Partnership Interests Transfer Withholding Tax
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April 3rd, 2018
On April 2, 2018, the Treasury Department and the Internal Revenue Service in the United States issued a guidance on the withholding on the transfer of non-publicly traded partnership interests, but exemptions or reductions from the withholding tax is possible for some qualifying cases.
General Tax Treatment .

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