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Joe Calianno is a Tax Partner and serves as BDO’s International Technical Tax Practice Leader. He also is a former Special Counsel to the Deputy Associate Chief Counsel (International) in the office of Chief Counsel for the Internal Revenue Service (IRS). Additionally, Mr. Calianno is a member of the AICPA’s Tax Executive Committee, and previously … Read More
It may sound like a cliché, but I am convinced that the future is just around the corner. I mean the real future. The future we used to see in movies from the 80s, where technology had reached its highest point and was used for simplifying people’s lives, changing the way we lived. Sounds promising, … Read More
On February 13, 2018, South Korea’s Ministry of Strategy and Finance (MOSF) issued an Enforcement Decree to provide guidance on the 2018 tax reform legislation, enacted on December 19, 2017, which includes the BEPS Action 2, 4, and 13 measures discussed below. Hybrid Mismatch Rules (BEPS Action 2) Hybrid mismatch arrangements exploit differences in … Read More
The Tax Cuts and Jobs Act includes some key impacts to transfer pricing, including the limitations on interest expenses imposed by section 163(n). BEPS Action 4 proposed two types of limitations on intercompany interest deductions: limits to intercompany debt where an affiliate’s debt to asset ratio mirrors the overall third party debt to asset ratio … Read More
On March 21, 2018, Sweden’s Ministry of Finance issued draft legislation to amend Sweden’s corporate tax rules, including to implement anti-hybrid mismatch and interest expense limitation rules based on the EU Anti-Tax Avoidance Directive (ATAD 1) issued on July 12, 2016, and the May 19, 2017, amendments … Read More
In keeping with President Trump’s stated desire to assist the U.S. aluminum and steel production industries, he has issued orders to impose special duties on aluminum and steel imports into the U.S. under the authority of section 232 of the Trade Expansion Act of 1962. In other words, he is declaring that the national security … Read More