Tax & Accounting Blog

BDO Webcast Analyzes Proposed U.S. Section 385 Regulations

BDO Webcast Analyzes Proposed U.S. Section 385 Regulations

On August 2, 2016, BDO held a webcast on the U.S. Section 385 Proposed Regulations (“Proposed Regulations”), concerning treatment of direct or indirect interests in a related corporation as stock, debt, or as in part stock and in part debt. The panelists included Joseph Calianno, Partner, International Technical Tax Practice Leader … Read More

Liechtenstein Initiates Consultation on Implementation of CbC Reporting

Liechtenstein Initiates Consultation on Implementation of CbC Reporting

On July 5, 2016, the Liechtenstein government initiated a consultation on the implementation of Country-by-Country (CbC) reporting and the OECD’s Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (“CbC MCAA”). See BEPS Action 13. The consultation will run until August 2, 2016, and the measures would apply … Read More

U.S. IRS Revises Chief Counsel Notice on Section 385

U.S. IRS Revises Chief Counsel Notice on Section 385

On June 30, 2016, the U.S. Internal Revenue Service (IRS) Chief Counsel issued Notice CC-2016-009. This notice alerts attorneys that the Chief Counsel Directives Manual (CCDM) has been revised to reflect updated requirements for coordinating issues, code sections, and documents with the appropriate Associate Chief Counsel in the National Office. The Office of … Read More

Liechtenstein Opens Consultation on Implementation of Beneficial Ownership Register

Liechtenstein Opens Consultation on Implementation of Beneficial Ownership Register

On July 12, 2016, Liechtenstein released a 193-page consultation on the implementation of a beneficial ownership registry in line with the Fourth EU Anti-Money Laundering Directive (EU 2015/849). Companies would have to disclose the identities of their ultimate owners under a proposal to come in line with European anti-money laundering recommendations. See … Read More

Germany Implements Changes to the EU Mutual Assistance Directive

Germany Implements Changes to the EU Mutual Assistance Directive

On July 13, 2016, the German Federal Ministry of Finance issued a press release saying that the German Federal Cabinet has adopted draft legislation adding new anti-avoidance measures and implementing OECD and EU standards on automatic exchange of information and transfer pricing documentation. The EU issued Directive 2015/2376, amending Directive … Read More