Tax & Accounting Blog

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

Romania Issues Guidance on Automatic Exchange of Financial Account Information

Romania Issues Guidance on Automatic Exchange of Financial Account Information

On August 24, 2016, Romania’s Ministry of Public Finance issued guidance (Order No. 1939/2016) on automatic exchange of financial account information (AEOI) under the U.S. Foreign Account Tax Compliance Act (FATCA) regime and OECD Common Reporting Standard (CRS). Financial institutions in Romania have to begin reporting FATCA information by August 31, 2016, and … Read More

U.S. Treasury Seeks Comments on CbC Reporting Form

U.S. Treasury Seeks Comments on CbC Reporting Form

On August 22, 2016, Treasury published a notice in the Federal Register seeking comments on IRS Form 8975 (Country-by-Country Report), which ultimate parent entities of U.S. multinational enterprise (MNE) groups will use for country-by-country (CbC) reporting purposes. Written comments are due by September 21, 2016. The notice says that “businesses or … Read More