International
More Transparency in the EU: Questions & Answers on DAC 6
Are you up to date on cross-border arrangements?
The European Union (EU) passed a sixth version of its Directive on Administrative Cooperation in the Field of Taxation, known as DAC 6 (EU Council Directive 2018/822), on May 25, 2018. DAC 6 introduces reporting requirements for professional intermediaries (and, under certain circumstances, taxpayers) relating to their involvement in a… Read more »
OECD Races Toward Completing Final Report on Digital Economy
But two fundamental “pillars” present structural challenges
The Organisation for Economic Co-operation and Development (OECD) is racing toward meeting an ambitious target by the end of the year that could radically change the way all multinational enterprises (MNEs) are taxed. The target—a final report—was set forth in January 2019 under the cover of addressing the digital economy.1… Read more »
Unilateral Taxation of the Digital Economy
The fight is not over yet—it’s only beginning
Notwithstanding the recent efforts of the G20/OECD Inclusive Framework on BEPS (hereafter the IF) to develop a uniform, multilateral, and consensus-based solution for taxing the digital economy, legislatures and tax administrations around the world continue to propose and enact a host of largely uncoordinated digital services taxes (DSTs) and other… Read more »
Diving In: Platform Transactions and the OECD Digital Economy Effort
How the Model Rules address tax considerations related to the gig and sharing economy
Although much of the tax world has been focused on the Organisation for Economic Co-operation and Development’s two-pillar framework for addressing the tax challenges arising from the digitalization of the economy, a separate OECD effort with a potentially even broader reach is well underway. On February 19, 2020, the OECD… Read more »
Valuation Perspectives From Around the World
Increased analysis within financial reporting comes with increased levels of analysis required for tax reporting
The valuation of entities and assets is under greater scrutiny by tax authorities. Although valuation standards for tax purposes have generally lagged behind those for book purposes, new global standards require increased data, analysis, and support. This article will briefly review the developing and changing landscape and provide some practical… Read more »
Claiming a Foreign Tax Credit—How Exhausted Do You Really Have to Be?
Missteps by taxpayers in this area can be costly and result in avoidable double taxation
The Internal Revenue Service recognizes that “foreign government audits of U.S. taxpayers have become more frequent and, at times, more aggressive.”1 Consequently, the number of foreign tax contests and payments made by taxpayers to resolve those contests are on the rise. The IRS has signaled through its training materials and… Read more »
Deconstructing MAP and APA
Increased demand, new requirements to engage with IRS Examination, and efforts to come to terms with untested provisions of the TCJA have stretched APMA resources
In recent years, many taxpayers have effectively used mutual agreement procedure (MAP) cases and advance pricing agreements (APAs) to reduce or eliminate actual or potential double taxation due to inconsistent treatment of transactions with cross-border impact—most conspicuously for transfer pricing matters, but potentially for other issues as well. As the… Read more »
Understanding and Managing Privileges in Today’s Interconnected World
A complicated web of communications in a global world presents real-world challenges
Gone are the days when business and fashion trends developed regionally. Remember when certain clothing styles were unique to particular regions in the United States or to different countries? Or when certain foods were generally available only in certain parts of the world? Globalization has brought the world much closer… Read more »
When the IRS Says It’ll “Meet You in Paris”: Recent Trends & Developments in Outbound U.S. Exchange-of-Information Techniques
The FATCA rollout and other automatic EOI procedures mean that the IRS now has much more access to international tax information about U.S. taxpayers
The Internal Revenue Service is looking for your international tax data—that is, if the IRS doesn’t already have it. With the rollout of the Foreign Account Tax Compliance Act (FATCA) and other automatic exchange-of-information (EOI) procedures, the IRS is now receiving—and making use of—a large amount of international tax information… Read more »
The Proper Role of the Tax Department in an MNE’s Intercompany Transaction Framework
The tax department typically houses a company’s expertise in transfer pricing and is a major consumer of intercompany transaction details, but its responsibility for nonnative intercompany transaction functions can lead to significant risk and incremental income tax exposure
This article presents the challenges of collecting tax-related intercompany transaction information as well as common functional misalignments of intercompany-transaction-related responsibilities inside the multinational enterprise (MNE). It also identifies key intercompany transaction function subject matter expertise (SME) and aligns these SME units or individuals with specific intercompany transaction operations. This article… Read more »
The Burgeoning Importance of E-Invoicing Although the United States has not yet officially adopted e-invoicing,…
The Presumption of Correctness A common question tax directors ask when considering whether to…
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations As readers are well aware, almost a year ago, on…
TEI Roundtable No. 40 Foreign Tax Credit Regulations For almost four decades, the foreign tax credit regulations have…
Reconnecting at TEI’s Annual Conference I am very excited about TEI’s 77th Annual Conference, as…
Steve Saunders Steve Saunders gained an appreciation of the complexity of tax…