International
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 »
Indirect Taxes, Canada: Impact of Delivery Terms
Effect is significant on application of GST/HST on imports, exports, and sales
Canada imposes a five percent federal value-added tax called the goods and services tax (GST), which applies to the supply of most goods and services in Canada and to imports of most goods into Canada. Five Canadian provinces (Ontario, Nova Scotia, New Brunswick, Prince Edward Island, and Newfoundland and Labrador)… Read more »
Indirect Taxes, Canada: Cross-Border Developments
Court decisions, interagency tensions, and ETA amendments could significantly affect taxpayers doing business in Canada or with Canadian companies
Three recent Canadian goods and services/harmonized sales tax (GST/HST) developments may have significant consequences for and warrant close attention from those engaged in businesses either in Canada or outside Canada with business or financial interests in Canada, as well as their tax advisors. One of these concerns is whether the… Read more »
Indirect Taxes: United Kingdom
Brexit expected to affect tax policy for at least a generation
On June 23, 2016, the United Kingdom voted in a national referendum on whether the UK should remain a member of the European Union. It was a simple in-or-out question asked of the British people, of whom 51.9 percent voted to leave the EU and 48.1 percent voted to remain.… Read more »
Indirect Taxes: India
Goods and services consumption tax heralds new era
India is witnessing one of the most significant events in its fiscal history with the introduction of the goods and services tax (GST), a single comprehensive destination-based consumption tax. The country’s current indirect tax system consists of the following taxes levied by the federal and state governments: The GST framework… Read more »
Prepare for Public Country-by-Country Reporting With public country-by-country reporting (CbCR) on the horizon, companies with…
Question: How Can Companies Take Advantage of Digital Assets With No Tax Impact? Digital-asset-based loyalty and reward programs allow companies to create a…
The Rise of the Excise Tax In August 2022, Public Law No. 117-169—commonly called the Inflation…
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
Who Is the Customer? Compared to the complexity of cost-of-performance (COP) sourcing of services…
Navigating Tax Risk in the Modern Era: Why Tax Technology Is Essential In today’s ever-changing tax world, managing the organization’s tax risk…