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.

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.

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.

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.

Newsletter Articles

50th ANNIVERSARY

50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.