Tax & Accounting Blog

Final Regulations Issued on U.S. Property Held by CFCs in Partnership Transactions

Final Regulations Issued on U.S. Property Held by CFCs in Partnership Transactions

Treasury and IRS issued final regulations (Final Regulations) on partnership transactions where U.S. property is held by a controlled foreign corporation (CFC). See BEPS Action 3 and Internal Revenue Code (IRC) section 956. The Final Regulations were filed on November 2, 2016 and are scheduled to be published in … Read More

Will US Country-by-Country Voluntary Filing Offer A Reasonable Alternative to Fulfill 2016 Tax Year Obligations?

Will US Country-by-Country Voluntary Filing Offer A Reasonable Alternative to Fulfill 2016 Tax Year Obligations?

BEPS, Blog, ONESOURCE November 3, 2016

The US regulations provide that Country-by-Country (“CbC”) Reporting for US HQ MNEs must be filed with the ultimate parent entity’s income tax return for the taxable year beginning on or after June 30, 2016. In contrast, pursuant to the OECD guidance, CbC reporting is to become effective for fiscal years starting on or after January … Read More

Hong Kong Launches Consultation on Implementation of OECD BEPS Measures

Hong Kong Launches Consultation on Implementation of OECD BEPS Measures

As a major trading centre, Hong Kong's commitment to, and implementation of, the OECD/G20 BEPS measures is of considerable interest. Hong Kong is an Associate in the inclusive framework established by the OECD for implementing the BEPS package. In a significant development, the Hong Kong Government on October 26, 2016 launched a consultation … Read More

Ireland Updates Country-by-Country Reporting FAQs

Ireland Updates Country-by-Country Reporting FAQs

On October 13, 2016, Ireland updated its Country-by-Country Reporting Frequently Asked Questions (FAQs). The FAQs relate to the OECD BEPS Action 13 country-by-country (CbC) reporting requirements and the Irish legislation implementing these requirements. This legislation is included in section 891H of the Taxes Consolidation Act 1997 (TCA 1997)Read More