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.
U.S. Anti-Deferral Rules
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.
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.
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.
The consideration of a border tax adjustment on goods imported may persuade multinational businesses to reevaluate their intercompany supply chain, having transfer-pricing implications.
The IRS issued final regulations implementing new country-by-country reporting requirements.
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.
This item describes certain significant areas where the EC's tax-avoidance package differs from the OECD’s recommendations.
These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.
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.
The European Commission issued two proposed directives regarding international taxation.
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 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.
Proposals include automatic exchange of the information gathered under new 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.
The IRS announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.
The Organisation for Economic Co-operation and Development (OECD) issued proposals to address corporate international tax avoidance and harmonize global tax rules.
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.
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.