Tax & Accounting Blog

U.S. IRS Updates List of International No-Ruling Areas

U.S. IRS Updates List of International No-Ruling Areas

On January 3, 2017, the U.S. Internal Revenue Service (IRS) issued Revenue Procedure ("Rev. Proc.") 2017-7, superseding Rev. Proc. 2016–7, providing a current list of areas of the Internal Revenue Code (the “Code”), under the jurisdiction of the Associate Chief Counsel (International), on which the IRS will not issue letter rulings … Read More

The Personality Differentiator For More Business

The Personality Differentiator For More Business

Why should I hire you? What makes you unique from competitors? How are your services better than theirs? These are the common questions that marketers ask when developing a marketing plan. The simple fact is that your firm looks pretty much the same as all the others within your industry unless you can demonstrate and … Read More

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

On December 27, 2016, the Chilean tax authorities (Servicio de Impuestos Internos – SII) published Resolution No. 126 (the “Resolution”). The Resolution updates the current annual transfer pricing return (affidavit) requirements to introduce an associated country-by-country (CbC) reporting requirement. See BEPS Action 13. The new CbC requirements include the following: Annual … Read More

Brazil Publishes Country-by-Country Reporting Requirements

Brazil Publishes Country-by-Country Reporting Requirements

On December 29, 2016, Brazil published Normative Instruction RFB No. 1681, requiring country-by-country (CbC) reporting. See BEPS Action 13. The ultimate parent entity, or another entity that is a Brazilian tax resident, is required to submit the CbC report. An entity other than the ultimate parent can submit the report if … Read More

Luxembourg Publishes Extended Notifications for Country-by-Country Reporting

Luxembourg Publishes Extended Notifications for Country-by-Country Reporting

On December 27, 2016, Luxembourg published a newsletter, saying that the government has implemented country-by-country (CbC) reporting and the mandatory automatic exchange of CbC information. See BEPS Action 13. On December 13, 2016, the Luxembourg Parliament adopted Law No. 7031, implementing CbC reporting and the mandatory automatic exchange of … Read More

Country-by-Country Reporting Proposals Achieve Royal Assent in Canada

Country-by-Country Reporting Proposals Achieve Royal Assent in Canada

On December 15, 2016, Bill C-29 (“Bill”) received Royal Assent by the Canadian Parliament, implementing certain proposed and confirmed provisions from the March 22, 2016 budget. The Bill includes amendments to the Income Tax Act (“Act”) with respect to CbC reporting (proposed in March 22 budget) and the common reporting standard for the … Read More