Tax & Accounting Blog

UK Launches Worldwide Disclosure Facility

UK Launches Worldwide Disclosure Facility

On September 5, 2016, HMRC published the Guidance on the Worldwide Disclosure Facility (WDF) that is available for disclosure of a UK tax liability relating wholly or partly to an offshore interest. Prior to December 31, 2015, HM Revenue and Customs (HMRC) offered incentives to encourage taxpayers to voluntarily disclose their tax positions. … Read More

KPMG’s Joseph Pari on the U.S. Proposed Section 385 Regs.

KPMG’s Joseph Pari on the U.S. Proposed Section 385 Regs.

Joseph M. Pari is the national principal-in-charge of the Washington National Tax practice of KPMG LLP. He is based in Washington, D.C.  Prior to joining KPMG, he was a partner at the law firms of Linklaters LLP and Dewey Ballentine/Dewey & LeBoeuf LLP. Mr. Pari answered the following questions for BEPS Global Currents on September … Read More

Apple’s €13 billion Irish back-tax bill reverberates around the world – Apple and Ireland to appeal; U.S. denounces decision

Apple’s €13 billion Irish back-tax bill reverberates around the world – Apple and Ireland to appeal; U.S. denounces decision

Let the tax wars begin! A little too dramatic? Perhaps, but maybe not. The significance of the European Commission's decision effectively imposing a €13 billion (yes, €13 billion!) Irish back-tax bill on Apple should not be underestimated. While it may take a little time for the consequences to be fully worked through, the decision raises … Read More