The IRS announced new rules rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.
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International Tax
European Commission Issues Anti-Tax Avoidance Directives
Proposals include automatic exchange of the information gathered under new country-by-country reporting requirements.
Taxation of Outbound Transfers of Foreign Goodwill or Going Concern Value Under Secs. 367(a) and (d)
The regulations would eliminate the exception in the current temporary regulations for the transfer
of foreign goodwill and going concern value.
Recently Issued Regulations Will Increase Likelihood of Sec. 956 and Subpart F Income Inclusions
The regulations limit the application of the “active rents and royalties” exception to foreign
personal holding company income, expanding the instances in which a controlled foreign corporation will be treated as holding U.S. property.
Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules With Other Code Provisions
The regulations would clarify the application of the arm’s-length standard when multiple Code sections apply.
IRS Issues Updated Guidance on Requesting and Obtaining an APA
The IRS has issued updated guidance on requesting and obtaining an advance pricing agreement, modifying somewhat its proposed
revenue procedure published in Notice 2013-79.
Revised Procedures for Obtaining Assistance From U.S. Competent Authority, Including Discretionary Relief
The IRS published guidance on the process
of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority.
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.
Dividend-Equivalent Rules for NPCs and Equity-Linked Investments Are Issued
The IRS issued regulations that apply to certain financial products providing for payments that are contingent upon or determined by reference
to U.S.-source dividend payments.
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.
IRS Provides Guidance on FBAR Penalties
The guidance provides procedures to ensure consistency and efficiency in the IRS’s administration of the FBAR compliance program.
Rules Are Proposed on Sec. 2801 Tax on Gifts and Bequests From Expatriates
Taxpayers who receive gifts or bequests from individuals who gave up U.S. citizenship or residency will be subject to tax under proposed rules.
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.
The Problematic Use of Transparent U.S. LLCs by Foreign Taxpayers
This item explores some common issues encountered by foreign taxpayers adopting transparent U.S. LLCs to invest or operate in the United States.
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.
U.S. Enters First Agreements Implementing Automatic Information Exchange
The IRS announced that the United States has entered into agreements with Australia and the United Kingdom implementing procedures to automatically exchange financial account information pursuant to the Foreign Account Tax Compliance Act (FATCA).
IRS Issues Dividend-Equivalent Rules for Notional Principal Contracts and Equity-Linked Investments
The IRS issued regulations under Sec. 871(m) that govern withholding on dividend equivalents received by nonresident individuals and foreign corporations from sources within the United States.
Transfer-Pricing Arm’s-Length Standard and Transfers of Foreign Goodwill Clarified
Taxpayers will be required to consistently value transfer-pricing transactions for purposes of all Code sections under rules issued by the IRS.
Proposed Rules Govern Taxation of Gifts and Bequests From Covered Expatriates
Taxpayers who receive gifts or bequests from certain individuals who gave up their U.S. citizenship or residency will be subject to tax under rules proposed by the IRS on Wednesday.
Regulations Prevent CFCs From Using Partnerships to Avoid Sec. 956
The IRS issued temporary and proposed regulations governing the treatment of property held by a controlled foreign corporation in connection with certain transactions involving partnerships.
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