Tax & Accounting Blog

Corrected: U.S. May Not Finalize All CbCR Exchange Agreements by 2017 Deadline

Corrected: U.S. May Not Finalize All CbCR Exchange Agreements by 2017 Deadline

On October 27, 2017, a U.S. Internal Revenue Service (IRS) Large Business and International (LB&I) official, Theodore Setzer (Assistant Deputy Commissioner – International), said during an ABA Tax Section conference in Washington, D.C. that the IRS may not be able to sign some bilateral competent authority agreements (CAAs) in 2017 with its treaty partners … Read More

India Issues Final Rules on Master File and Country-by-Country Report Requirements

India Issues Final Rules on Master File and Country-by-Country Report Requirements

On November 1, 2017, the Indian Ministry of Finance issued a press release on the Central Board of Direct Taxes (CBDT) rules regarding transfer pricing documentation (TPD) in the master file and country-by-country (CbC) report. India has implemented the OECD BEPS Action 13 recommendations on TPD and CbC reporting by adding section … Read More

Australia: Making BEPS CbC reports public – “a shame to kill the golden goose”

Australia: Making BEPS CbC reports public – “a shame to kill the golden goose”

At an Australian Senate Estimates hearing on October 25, 2017, Australian Tax Commissioner Chris Jordan was asked to respond to calls for making country-by-country (CbC) reports public. He was asked whether releasing those reports to the public would be of help to the Australian Taxation Office (ATO). Mr. Jordan said if the reports were … Read More

India Extends Deadline for Filing Country-by-Country Reports

India Extends Deadline for Filing Country-by-Country Reports

On October 25, 2017, India’s Central Board of Direct Taxes (CBDT) issued Circular No. 26/2017 on the deadline for submitting a country-by-country (CbC) report. See BEPS Action 13. CBDT has extended the due date for submission of the CbC report, by the parent/reporting entity that is an Indian resident, for the reporting accounting … Read More

U.S. IRS Requests Comments on Disclosure of Reportable Transactions

U.S. IRS Requests Comments on Disclosure of Reportable Transactions

On October 20, 2017, the U.S. Treasury Department and the Internal Revenue Service (IRS) published a notice in the Federal Register requesting comments on Form 13976 (Itemized Statement Component of Advisee List), which provides material advisors a format for preparing and maintaining an itemized statement with respect to a reportable transaction. The IRS … Read More