Skip Page Banner  
About This Blog

The Bloomberg BNA International Tax Blog is a forum for practitioners and Bloomberg BNA editors to share ideas, raise issues, and network with colleagues. The ideas presented here are those of individuals, and Bloomberg BNA bears no responsibility for the appropriateness or accuracy of the communications between group members.

Blogroll
Skip Main Content

International Tax
RSS
BLOG

 

February 1, 2012

Incoming Saint-Amans Sees OECD Moving 'Back to Basics' in Transfer Pricing Approach

Pascal Saint-Amans, who takes office today as head of the Organization for Economic Cooperation and Development's Center for Tax Policy and Administration (CTPA), spoke with Bloomberg BNA correspondent Rick Mitchell about his outlook on the current global tax scene and his plans for the CTPA.

June 23, 2011

Is the IRS Changing Its Approach to Cost Sharing?

At the kick-off to the BNA-Baker & McKenzie transfer pricing conference June 8, keynote speaker Sam Maruca — the IRS's newly appointed director of transfer pricing operations — indicated the Service may be turning its back on the much-criticized September 2007 coordinated issue paper on cost sharing buy-ins.

June 20, 2011

One Small Step for Man…One Less Duplicate Information Reporting Requirement for Certain Corporations

2011-06-20 On June 9, 2011, the IRS announced that the duplicate filing requirement for Form 5472 will no longer be required.   In T.D. 9529, 76 Fed. Reg. 33997 (6/10/11), the IRS explained that duplicate reporting in the Form 5472 context is no longer necessary due to technological advances in electronic p

June 10, 2011

Repatriation Proposals Heat Up

On May 11, a bipartisan group of six Congressmen introduced H.R. 1834, the Freedom to Invest Act of 2011. The bill, whose lead sponsors are Ways and Means Committee member Kevin Brady (R TX) and Jim Matheson (D UT), would

June 3, 2011

Transfer Pricing Considerations Arising from Replacing U.S. GAAP with IFRS

KPMG practitioners Hareesh Dhawale and David Crosswy examine the potential impact of transitioning to international financial reporting standards on a company's intercompany pricing policies and on the methods used to test whether policies comply with the international arm's length standard.

June 3, 2011

BNA Transfer Pricing Reports Releases Two New Special Reports on Restructuring: One on China, One on Germany

BNA Tax & Accounting Transfer Pricing Report  has released two Special Reports on the tax treatment of business restructurings--one on Germany and one on China.

June 3, 2011

U.S. Budget Provision Designed to Capture Revenue from U.S. Businesses' ‘Excess' Intangibles Income in Low-Tax Jurisdictions

The Obama administration's fiscal year 2011 budget unveiled Feb. 1 contained a broad-ranging package of international tax provisions estimated to raise $122 billion over 10 years, including provisions to prevent shifting of high-value intangibles income out of the United States.

June 3, 2011

Time Running Out to Comment on FBAR Rules

On February 26, Treasury's Financial Crimes Enforcement Network (FinCEN) published in the Federal Register proposed regulations that would clarify who is required annually to file the FBAR. For those not in the know, "FBAR" is shorthand for Treasury Form TD F 90-22.1 , Report of Foreign Bank and Financial Accounts

June 3, 2011

U.S., Switzerland Announce Treaty Protocol

The United States and Switzerland signed a protocol March 31 allowing for the provisional application of their Aug. 19 agreement requiring Swiss bank UBS to hand over details on 4,450 secret bank accounts held by U.S. taxpayers.

June 3, 2011

IRS Chief Counsel Discusses Uncertain Tax Position Disclosure Schedule

IRS Chief Counsel William Wilkins answered a host of questions about the agency's proposed disclosure schedule for uncertain tax positions during a BNA webinar June 9, where he and international tax experts from the private sector engaged in a broad-ranging discussion of the many unanswered questions surroundin