As the OECD member states plan to review the
CbC framework in 2020, this discussion highlights several common issues large U.S. MNEs may face.
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Topics
U.S. Anti-Deferral Rules
IRS issues guidance on BEAT
The IRS issued detailed guidance on the Sec. 59A base-erosion and anti-abuse tax (BEAT), which was added to the Code by the law known as the Tax Cuts and Jobs Act.
Missing links: Tax reform’s impact on the value chain
In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.
OECD releases additional guidance on country-by-country reporting and updated exchange relationships
The OECD guidance aims to give greater certainty to tax administrations and multinational enterprise groups on the implementation and operation of BEPS Action 13 Country-by-Country Reporting.
Proposed regs. govern tax on base-erosion payments
The IRS issued proposed rules on the Sec.59A base-erosion anti-abuse tax (BEAT), one of a number of new international tax provisions added by the law known as the Tax Cuts and Jobs Act.
How a border tax could affect a company’s transfer pricing
The consideration of a border tax adjustment on goods imported may persuade multinational businesses to reevaluate their intercompany supply
chain, having transfer-pricing implications.
IRS Finalizes Country-By-Country Reporting Regulations
The IRS issued final regulations implementing new country-by-country reporting requirements.
Final Rules Govern U.S. Country-by-Country Reporting
The IRS issued final regulations requiring the ultimate parent entity of a multinational enterprise group with revenue of $850 million or more in the preceding accounting period to file Form 8975, Country-by-Country Report.
Adopting BEPS in the EU: The Impact of the EC’s Anti Tax Avoidance Package
This item describes certain significant areas where the EC’s tax-avoidance package differs from the
OECD’s recommendations.
IRS’s Inversion Rules Include Earnings-Stripping Provisions
These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.
Panama Papers Leak Provides Road Map for Tax Investigations
Tax authorities in various countries announced the launch of investigations after 11.5 million documents were leaked from a Panamanian law firm that specializes in setting up offshore entities.
Anti-Tax Avoidance Directives Issued by European Commission
The European Commission issued two proposed directives regarding international taxation.
Country-by-Country Reporting Rules Are Issued in Proposed Form
To conform U.S. procedures with the BEPS project to prevent multinational companies from shifting profits to low- or no-tax jurisdictions, the IRS issued proposed rules
governing reporting by any U.S. person that is the “ultimate parent entity” of a multinational enterprise.
The Common Reporting Standard: Impact on Financial Services Institutions
The CRS requires financial institutions resident in participating jurisdictions to implement due-diligence procedures, to document and identify reportable accounts, and to establish a wide-ranging reporting process.
European Commission Issues Anti-Tax Avoidance Directives
Proposals include automatic exchange of the information gathered under new country-by-country reporting requirements.
Proposed Regulations Outline Country-by-Country Reporting Requirements
The much-anticipated rules, under which the US would adopt the Organisation for Economic Co-operation and Development’s country-by-country reporting regime, would require reporting by multinational enterprise groups with revenue of $850 million or more in the prior annual accounting period.
New Corporate Anti-Inversion Rules Issued
The IRS announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.
OECD Proposes Widespread Changes to International Tax Rules
The Organisation for Economic Co-operation and Development (OECD) issued proposals to address corporate international tax avoidance and harmonize global tax rules.
BEPS Action 7: Preventing the Artificial Avoidance of Permanent Establishment Status
The stated purpose of Action 7 is to attack certain “artificial” arrangements nonresident enterprises have entered into to avoid having a taxable presence in a country.
BEPS Country-by-Country Reporting: The Practical Impact for Corporate Tax Departments
The OECD’s Action Plan on Base Erosion and Profit Shifting included the highly anticipated final version of its recommended country-by-country reporting template.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
