Tax & Accounting Blog

On September 7, 2016, Irish Finance Minister Michael Noonan spoke to the House of Representatives (Dáil Éireann), seeking support to appeal the European Commission's decision that tax rulings issued by Ireland to Apple in 1991 and 2007 constituted illegal stated aid. On the same date, the Irish Department of Finance issued … Read More

The UK Parliament has been debating the large omnibus Finance Bill 2016 which, among other things, contains amendments concerning transfer pricing (application of OECD principles) as well as other amendments re hybrid mismatches, DPT amendments, a patent box regime in the UK, GAAR, etc. A critical amendment to the Bill, agreed to by … Read More

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

While there may be perfectly valid business reasons for generating multiple commercial invoices for a single import transaction, the mere existence of a dual invoice model is likely to set off alarms if discovered by Customs and Border Protection (CBP) Import Specialists or Auditors, and Immigration and Customs Enforcement (ICE) Special Agents.  That is why … Read More

On July 14, 2016, Bill H.R. 5893, titled “No Regulation Without Representation Act of 2016”, was introduced to the House. This bill is to regulate the State’s imposition of sales/use tax on interstate commerce by creating specific standards for nexus, and in effect, the sales/use tax collection requirement on behalf of a state. H.R. … Read More

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