Tax & Accounting Blog

South Korea: Tax Revision Bill, 2016 to Make Significant Tax Changes: CbC Reporting

South Korea: Tax Revision Bill, 2016 to Make Significant Tax Changes: CbC Reporting

South Korea’s government says its 2016 Tax Revision Bill focuses on stimulating the economy and improving people’s livelihoods, while pursuing fair and rational taxation. The Ministry of Strategy and Finance says the Bill provides for a range of changes, including Country-by-Country (CbC) reporting under BEPS, R&D incentives, corporate tax credits, tax … Read More

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