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  • Proposed Section 385 Regulations Go Way Too Far

    Bloomberg

    by James J. Tobin

    James J. Tobin of Ernst & Young examines documentation and information reporting standards and “per se stock” rules proposed under earnings-stripping regulations (REG-108060-15). 
    To read more go here Subscription Required
    By Tobin, James J., posted on Wednesday August 24, 2016
  • GOP Taxwriters Ask Lew to Explain His Role in Debt-Equity Regs

    by Kat Lucero
    Seven Senate Finance Committee Republicans are demanding that Treasury Secretary Jacob Lew explain his role during what may seem to be the final stretch in approving the controversial proposed debt-equity regs.
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    By Lucero, Kat, posted on Thursday August 25, 2016
  • Treasury: EU State Aid Investigations Undermine BEPS Project

    by Ryan Finley
    By creating a unique interpretation of the arm's-length principle that strays from the OECD transfer pricing guidelines without offering any coherent guidance as to how it will be applied, the European Commission may threaten the consensus achieved through years of negotiation during the base erosion and profit-shifting project, according to a Treasury white paper.
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    By Finley, Ryan, posted on Thursday August 25, 2016
  • U.S. Treasury Ups Pressure on EU Over Apple, Other Inquiries

    The U.S. is stepping up its effort to convince the European Commission to refrain from hitting Apple Inc. and other companies with a demand for possibly billions of euros in underpaid taxes.
    In a white paper released Aug. 24, the Treasury Department said the Brussels-based commission is taking on the role of a “supra-national tax authority.”
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    By Saleha Mohson, posted on Friday August 26, 2016
  • Republicans Keep Up Pressure on Debt-Equity Regulations

    Bloomberg

    by Kaustuv Basu
    Seven Republican senators are questioning whether the Treasury Department is taking into account lawmakers’ concerns about controversial debt-equity regulations.
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    By Basu, Kaustuv, posted on Wednesday August 24, 2016
  • Debt-Equity Rules Big Concern for ABA Tax Section: New Chair

    Bloomberg

    by Alison Bennett

    Action on the controversial rules to curb multinational companies from stripping income out of the U.S. through loans to subsidiaries remains one of the highest priorities of the American Bar Association Section of Taxation, its incoming chair told Bloomberg BNA.
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    By Bennett, Alison, posted on Wednesday August 24, 2016
  • OECD releases discussion draft on branch mismatch structures

    PwC

    by PwC
    On 22 August 2016 the OECD published, for discussion, recommendations for domestic laws that would neutralise the effect of payments involving certain branch mismatch arrangements. 
    This expansion of the final Base Erosion and Profit Shifting (BEPS) Action 2 paper, Neutralising the Effects of Hybrid Mismatch Arrangements, issued on 5 October 2015, adds even more complexity to that very long and complicated hybrid mismatch guidance.
    To read more go here
    By PwC, posted on Thursday August 25, 2016
  • Puerto Rico's Wal-Mart' Tax Invalid, Appeals Court Holds

    Bloomberg

    by Dolores W. Gregory
    Puerto Rico's alternative minimum tax is unconstitutional on its face, a federal appeals court ruled, affirming a lower court's injunction that bars enforcement of the tax against Wal-Mart Puerto Rico Inc. (Wal-Mart P.R., Inc. v. Zaragoza-Gomez, 1st Cir., No. 16-01370, 8/24/16).
    The U.S. Court of Appeals for the First Circuit said Aug. 24 that it is “indisputable” that the AMT unfairly targets cross-border transactions. 
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    By Gregory, Dolores W., posted on Friday August 26, 2016
  • Ireland, U.S. to Renegotiate Tax Treaty

    The U.S. and Ireland are renegotiating their 1997 income tax treaty, which was amended by a protocol in 1999.
    “Discussions have begun” with the U.S. Treasury Department “on updating certain elements” of the double tax treaty, the Irish Finance Department said in an Aug. 25 announcement.
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    By Bell, Kevin A., posted on Thursday August 25, 2016
  • OECD Interest Deduction Rule May Spur Different Approaches

    by Alex M. Parker
    New OECD rules to limit excessive interest deductions might be interpreted differently in different countries, increasing compliance costs for taxpayers, according to several law and accounting firms, as well as other business associations.
    The concerns were raised in comments to the Organization for Economic Cooperation and Development, which issued a draft of suggested legislation on a “group ratio rule” for countries to use as a way to limit interest deductions based on intercompany debt. 
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    By Parker, Alex M., posted on Thursday August 25, 2016