In a previous post on the new OECD Base Erosion Profit Shifting (BEPS) project recommendations, I advised that multi-national companies or enterprises (MNE’s) should evaluate their tax risks and exposures in light of the increased attention given to transfer pricing by tax authorities in this new environment. 327 more words
Tags » International Tax
The IRS recently announced in Notice 2014-51, 2014-40 IRB that certain Mark-to-Market (“MTM”) taxpayers will be exempted from PFIC reporting rules, effective for tax years ending on or after December 31, 2013. 446 more words
International tax noncompliance remains a significant area of concern for the IRS. However, the IRS’s collection efforts need to be enhanced to ensure that delinquent international taxpayers become compliant with their U.S. tax obligations.
The EU Commission is suggesting that Apple should have been paying more tax and that Ireland aided them in achieving that outcome. If Apple was compliant with legislation / regulation at the time they should not be thrown under the bus of inappropriate transfer pricing practices and being a poor global (corporate) citizen . 159 more words
Almost 300 senior tax officials from more than 100 countries and international organisations met in Paris on September 25-26, 2014, during the 19th Annual Global Forum on Tax Treaties to discuss solutions to unintended double non-taxation caused by base erosion and profit shifting (BEPS). 153 more words
In a recent court case, the taxpayer who argued that by living in Germany for many years and selling his US properties a long time back, he had relinquished his Lawful Permanent Residence (LPR) or a green card and hence should not be subject to US taxes on his income. 251 more words