Tax & Accounting Blog

Ireland’s Corporate Tax Strategy and BEPS

Ireland’s Corporate Tax Strategy and BEPS

On July 31, 2018, Ireland’s Department of Finance released its Corporation Tax Strategy Report (TSG 18/01), dated July 10, 2018. The report discusses Ireland’s proposals with respect to taxing the digital economy, hybrid mismatches, controlled foreign companies (CFCs), limitation on interest deductions, and the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent … Read More

Has Article 1 of the TFA Become a Casualty of Donald Trump’s Trade War?

Has Article 1 of the TFA Become a Casualty of Donald Trump’s Trade War?

As discussed in an earlier post (Shouldn’t Governments be Doing more to Fulfill the Promise of the TFA Article 1?), the Trade Facilitation Agreement mandates that each World Trade Organization member promptly publish tariff and regulatory trade information in an “easily accessible manner”. This requirement is being tested to its limits … Read More

Canada Publishes 2017 Report on Advance Pricing Arrangements

Canada Publishes 2017 Report on Advance Pricing Arrangements

On July 12, 2018, the Canada Revenue Agency (CRA) published Advance Pricing Arrangement: Program Report 2017. See BEPS Action 14. The CRA offers the program to assist taxpayers in preventing future transfer pricing (TP) disputes, and to provide increased certainty for transfer pricing methodologies for future intercompany TP transactions (e.g., to establish a … Read More

Reacting to Customs and Border Protection’s (CBP) Ruling Changes

Reacting to Customs and Border Protection’s (CBP) Ruling Changes

Importers today are engaged in complex supply chains where products cross borders multiple times to take advantage of special duty savings programs, free trade agreements, and other manufacturing cost considerations.  It is important to stay on top of the rules for allowing special duty exemptions since there are occasions when CBP will reconsider rulings previously … Read More