International

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 »

Nuts, Bolts, and Nuances of the Competent Authority Process
Relief is provided in most cases, but pitfalls and new issues are multiplying

The competent authority procedure is a dispute resolution mechanism available to taxpayers facing cross-border disputes under an applicable tax treaty. The taxpayer may invoke this procedure to require the tax administration’s competent authority function to “endeavor” to resolve the dispute by “mutual agreement” with its counterpart in the treaty partner… Read more »

Tax-Efficient Supply Chain in Shadow of Tax Reform
GILTI, FDII, and BEAT: they’re not just acronyms—they require reassessing tax consequences of existing supply chain structures

For the past quarter century the same legal framework and economic incentives have driven how multinational corporations structure their supply chains. Relatively high U.S. corporate rates incentivized companies to locate valuable assets and operations in lower-taxed jurisdictions; the United States’ worldwide tax regime incentivized retaining and reinvesting those earnings outside… Read more »

Anatomy of a Multijurisdictional Dispute
Recent tax reform presents additional considerations

Demands on tax executives have never been higher. Whereas international tax rules have always been complex, the Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting (BEPS) Action Plan and now U.S. tax reform introduce new levels of complexity and uncertainty. At the same time, sensational media coverage… Read more »

Practical Questions for Multinationals in an MLI World
MLI moves to implementation with open issues and challenges

Now that the multilateral instrument (MLI)1 coordinated by the Organisation for Economic Cooperation and Development (OECD) has been signed by over seventy jurisdictions,2 the new international tax agreement has moved to the implementation phase, with open issues and challenges ahead. The practical outgrowth of the OECD’s project to address base… Read more »

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