Tax & Accounting Blog

BEPS and the Allocation of Taxing Rights

BEPS and the Allocation of Taxing Rights

Author: David Spencer, an attorney in New York City, is a member of the Board of Advisors of the Journal of International Taxation and a frequent contributor. Recently, the Journal of International Taxation published a three-part article that deals with the allocation of taxing rights between jurisdictions.  This is a major international tax issue.  The OECD/G20 … Read More

OECD Releases Additional Guidance on Country-by-Country Reporting

OECD Releases Additional Guidance on Country-by-Country Reporting

On September 6, 2017, the OECD’s Inclusive Framework on BEPS released two sets of guidance for tax administrations and MNE groups regarding the implementation and operation of country-by-country (CbC) reporting. See BEPS Action 13. Existing guidance on the implementation of CbC reporting has been updated to address the following issues: Definition of … Read More

EFTPS email system is live

EFTPS email system is live

In 2012, the IRS initiated Rev. Proc. 2012-32. This ruling made it mandatory for all payroll service providers (PSP) to inform their clients — initially upon contract and at least every quarter — that they are filing returns and/or paying taxes on behalf of the clients. The PSP were supposed to encourage their clients to … Read More

U.S. IRS Publishes List of Negotiating Countries for the Exchange of Country-by-Country Reports

U.S. IRS Publishes List of Negotiating Countries for the Exchange of Country-by-Country Reports

The U.S. Internal Revenue Service (IRS) has updated its country-by-country (CbC) reporting jurisdiction status table, as of August 29, 2017, to include jurisdictions that are negotiating bilateral competent authority arrangements (CAAs) with the U.S. to exchange CbC information. The table also includes jurisdictions that have signed a CAA with the U.S. to exchange CbC … Read More