News North America & Canada
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 .
US Equipment Manufacturing Giant Could Face $2B Of Tax Bill From IRS
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February 1st, 2018
Caterpillar, the American Giant specialized in machinery and equipment manufacturing, has been negotiating with the US Inland Revenue Service(IRS) since last March when the officers raided Caterpillar’s offices and warehouses in Illinois. Now it could face a tax bill of 2 billion dollars from the IRS.
IRS Released Five Directives On Transfer Pricing
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January 23rd, 2018
The IRS Large Business and International (“LB&I”) Division released five Directives on new transfer pricing examination procedures and policies. All these Directives enter into force on their publication date.
US Disputes Guam & American Samoa To Be Included In The EU Blacklist
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January 10th, 2018
The US Treasury Secretary Steven Mnuchin has recently sent a letter to the EU Secretary General Jeppe Tranholm-Mikkelsen. In the document, the US presents its position in the BEPS project and Global Forum, as well as expressing its counterview on the EU Blacklist of Non-Cooperative Jurisdictions for tax purpose released by the European Council on December 5, 2017.
US Conference Committee Issues Unified Tax Reform Bill
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December 19th, 2017
Members of the Tax Cuts and Jobs Act (H.R. 1) House-Senate Conference Committee signed the conference report for this legislation. The bill is now moving forward to be voted on 19th or 20th by the entire House of Representatives and Senate.

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