Tags » International Tax

How should multi-national companies assess tax risks and exposures related to transfer pricing?

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

International Tax

Chile: Law No. 20.780 has enacted with different aspects

A tax reform entitled “Law No. 20.780” related to foreign investor has published on 29 September 2014 which is effective from 1st October 2014. This creates different regimes subject to Corporate Income Tax (CIT) from 1st January 2017. 76 more words


New Exception to PFIC Reporting for Mark-to-Market Taxpayers

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


Bitcoins: tax implication in the U.S.A.

According to Internal Revenue Service (IRS) Notice 2014–21, the IRS will treat bitcoins as property for tax purposes, applying rules it uses to govern stocks and barter transactions. 131 more words


The IRS' International Collection Efforts Not Up to Par, TIGTA Audit Finds

International Financial Law Prof Blog.

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.


Apple , Ireland and the European Commission

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


Governments Meet To Discuss BEPS Solutions

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