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

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

U.S. Treasury Sees Opportunity for Business Tax Reform

U.S. Treasury Sees Opportunity for Business Tax Reform

On September 12, 2016, the U.S. Department of the Treasury (Treasury) issued a press release, regarding an article written by Secretary Jacob J. Lew, discussing how the negative reaction by Congress to the European Commission’s (EC’s) recent state aid investigations could lead to an opportunity for business tax reform. On February 11, 2016, … Read More

Ireland House of Representatives Supports Appeal of Apple State Aid Ruling

Ireland House of Representatives Supports Appeal of Apple State Aid Ruling

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

UK Parliament agrees to give HM Treasury power to require public CbC reporting

UK Parliament agrees to give HM Treasury power to require public CbC reporting

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