International Tax
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February 1, 2012
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
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
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
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
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 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
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
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
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 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