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Archives: November 2018Subscribe
The proposed foreign tax credit regulations include extremely complex rules regarding allocation of expenses, among numerous issues, but largely follow the approaches practitioners thought Treasury would take.
By Alexander Lewis
Treasury’s narrowed scope for forthcoming rules on previously taxed income (PTI) will include guidance on some of the ordering rules, but answers to other PTI questions will have to wait until the spring.
By Andrew Velarde
Predictions that the IRS’s advance pricing and mutual agreement program would face a surge in disputes with foreign tax authorities emboldened by the base erosion and profit-shifting project have thus far failed to materialize.
By Ryan Finley
Apprehension over a potential patchwork of digital taxation measures could compel countries to achieve consensus by 2020.
By Jennifer McLoughlin
New voluntary disclosure guidelines apply to both foreign and domestic disclosures and include a penalty framework and access to Appeals.
By Nathan J. Richman
An individual has commented on a possible disconnect between the broad definition of interest in proposed section 163(j) regulations (REG-106089-18) and the narrower definition of interest expense in proposed regs (REG-104390-18) on global intangible low-taxed income regarding interest expense allocations.
By Tax Analysts
By Danish Mehboob
Treaty shopping is still a common practice among taxpayers when investing in Africa, and Mauritius remains one of the best jurisdictions for minimising tax liabilities.
By Alexander Hartley
Japanese businesses are nervous that public pressure could again postpone an increase to the consumption tax rate, further delaying the overhaul of the tax system that they want.
By James Freeman
Despite concerns over trade disputes and a slowing global economy, the corporate tax rate cut enacted in December of 2017 continues to encourage the business investment that leads to higher productivity and higher wages for American workers. Today the government reported that such investment was higher than it initially reported for the third quarter of the year.
By Richard Rubin
The Treasury Department issued long-awaited corporate tax regulations on Wednesday, partly accommodating companies’ pleas for help with an unexpected consequence of last year’s tax law.
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