Tax & Accounting Blog

U.S. Representative Introduces Act to Require Public Country-by-Country Reporting

U.S. Representative Introduces Act to Require Public Country-by-Country Reporting

On September 22, 2016, U.S. Representative Mark Pocan issued a press release, saying that he has introduced the Corporate Transparency and Accountability Act (the Act) to increase transparency regarding tax avoidance and profit shifting activities. This legislation would require the public disclosure of country-by-country (CbC) information. See BEPS Action 13. Representative Pocan said, “My … Read More

Brazil and Argentina – COD – Digital Certificate of Origin

Brazil and Argentina – COD – Digital Certificate of Origin

Ministers from Brazil and Argentina signed a document in order to guide the technical areas of both countries to continue with the Digital Certificate of Origin Pilot Project (COD), aiming to extend and deepen the bilateral trade as well as to promote integration between Brazil and Argentina. In addition, the deal with the Digital Certificate … Read More

Treasury and IRS Issue Foreign Tax Credit Guidance in Response to State Aid Investigations

Treasury and IRS Issue Foreign Tax Credit Guidance in Response to State Aid Investigations

Following the European Commission's (EC’s) state aid decision regarding Apple (see BEPS Action 5), the U.S. Department of the Treasury (Treasury) issued Notice 2016-52 stating that the U.S. Internal Revenue Service (IRS) and Treasury intend to issue new regulations under Internal Revenue Code (IRC) section 909 that will prevent … Read More