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| Title | Summary | Date |
|---|---|---|
| State and local tax considerations: nexus | Some recent court decisions have reignited taxpayer interest on a state’s authority to impose its taxes on out-of-state businesses. Does your business have taxable nexus? | 20121001October 2012 |
| Indirect Tax Briefing, Issue 5 - August 2012 | A review of global indirect tax developments and issues covering current trends and country updates from Australia, Brazil, Czech Republic, Hungary, India, Mexico, and Russia. | 20120901September 2012 |
| Navigating a complex tax controversy landscape | Read about our 2011–2012 Tax risk and controversy survey report, as well as insights on the research credit, transfer pricing and IRS section 162. | 20120801Summer 2012 |
| IRS issues LB&I directive on partial worthlessness deductions under Section 166(a)(2) taken by insurance companies | The Service has issued a Large Business & International (LB&I) Industry Director Directive (an IDD) addressing partial worthlessness deductions under Section 166(a)(2) taken by insurance companies for eligible loans | 20120801August 2012 |
| 2012 global transfer pricing tax authority survey | Tax authorities are increasing their transfer pricing staffing and the documentation burden is growing. Learn more about these trends and others in our global survey. | 20120701August 2012 |
| Washington Dispatch (Volume 16 Issue 7) | In this issue...1) Congress reviews tax reform options; territorial tax system enters presidential politics. 2) FATCA Model Intergovernmental Agreement released. 3) Notice 2012-39 announces regulations to be issued under Section 367(d) affecting certain outbound transfers of intangible property in asset reorganizations... | 20120730July 2012 |
| State income tax quarterly update | Read a summary of the legislative, administrative and judicial updates that occurred during the second quarter of 2012. | 20120701July 2012 |
| Tax credits and incentives: key trends and leading practices | Our 2011 survey shows the importance of local, regional and even global tax credits, cash grants and related business incentives (C&I) is on the rise. | 20120701July 2012 |
| Additional Medicare tax on high-wage earners | Significant changes in the Medicare tax are effective January 1, 2013. Read answers to frequently asked questions based on IRS guidance and our insights. | 20120701July 2012 |
| Navigating the road ahead: State unemployment insurance management | Unemployment insurance costs are at an all-time high and continue upward as trust funds work to become solvent. Read our 2012 guide for more facts. | 20120701July 2012 |
| The rise of indirect taxation: what it means for business | Governments around the world are turning to indirect taxes as a revenue raising measure. Issue 08 of T Magazine examines how these policy changes affect businesses. | 20120701July 2012 |
| TradeWatch, June 2012 | Read latest issue of TradeWatch, our global customs and international trade publication. | 20120701July 2012 |
| Talk about it: tax risk and controversy | Increased media focus on how businesses pay taxes is part of the riskiest tax controversy environment in years. How are leading companies reducing these risks? | 20120701July 2012 |
| Tax Policy & Controversy Quarterly Briefing, June 2012 | This edition brings into focus many recent developments of the global tax landscape, including changes in a series of high-profile tax leadership positions. | 20120601June 2012 |
| Managing indirect taxes in the supply chain | Effective management of indirect taxes, grants and incentives is essential to support growth and reduce the costs and risks of doing business internationally. | 20120501May 2012 |
| Evaluating the effectiveness of state film tax credit programs | Our report discusses issues that need to be considered and alternative approaches used when evaluating state film credit programs. | 20120501May 2012 |
| Global executives – a new breed of manager takes center stage | Issue 07 of T Magazine looks at how companies are developing global talent management processes and explores the tax implications of this increasingly mobile workforce. | 20120501May 2012 |
| New tangible property regulations have implications for US multinational companies | These new rules apply not only for purposes of computing taxable income of US taxpayers, but also for purposes of computing earnings and profits (E&P) of US-owned foreign corporations. | 201204April 2012 |
| US and German competent authorities agree not to tax dividends received by certain pension funds | On 12 April 2012, the Internal Revenue Service announced that the US and German competent authorities had reached a mutual agreement (the Agreement) regarding the eligibility of certain specified pension funds for the dividend withholding tax exemption under Article 10(3)(b) of the US – German Income Tax Treaty. | 201204April 2012 |
| Final regulations require payers to report bank deposit interest paid to nonresident aliens | Treasury has issued final regulations (T.D. 9584) requiring payers to report payments of interest aggregating $10 or more on deposits maintained at a US office of a financial institution by certain nonresident alien (NRA) individuals. Such reporting will be required on Forms 1042-S, Foreign Person’s U. S. Source Income Subject to Reporting. | 20120401April 2012 |
| Indirect Tax in 2012 | Indirect taxes continue to grow at a record pace as governments everywhere search for the most growth-friendly ways to raise revenue. Learn what 2012 may bring in our new global report. | 20120401April 2012 |
| Tax policy and controversy outlooks for 2012 | The pace of tax policy change, legislative and regulatory, continues to accelerate globally. Our regional reports provide you with clarity about the shifting tax landscape. | 20120301March 2012 |
| Global trade management: adapting to polycentric markets | This new report summarizes the findings and identifies leading practices from the 2011 Ernst & Young LLP Customs and International Trade Symposium. | 20111201December 2011 |
| Ernst & Young's 2011–12 Tax risk and controversy survey | Our survey report examines how a convergence of trends is driving increased financial and reputational risks for global businesses. The survey indicates that the risks are imminent and growing in volume and complexity. Some are unpredictable and others unavoidable; now is the time to plan a course of action to manage them. | 20111101November 2011 |
| Global M&A tax survey and trends: The growing role of the tax director | The harder that company boards press for deals to deliver the value they promise, the more that tax directors play a critical role in identifying and delivering that value. That's the message in our second annual review of trends affecting tax aspects of corporate mergers and acquisitions. | 20111201November 2011 |
| 2011 Global Mobility Effectiveness Survey | Our fourth survey on global mobility analyzes the trends in changing global mobility strategies, policies and processes of 350 companies, higlighting how leading companies are reacting to the challenging external environment. | 20111001October 2011 |
| The role of tax in a changing climate | In issue 05 of T Magazine, we explore the sustainability agenda in the context of a rapidly evolving fiscal and regulatory environment. | 20110901September 2011 |
| Global Tax Policy & Controversy Quarterly Briefing - August 2011 | We've heard from you that tax policy and controversy issues are becoming a top priority at the C-suite and board level. Stay up-to-date with our briefing. | 20110801August 2011 |
| Indirect Tax Briefing: stay up-to-date | Companies around the world are telling us that indirect taxes are rising up the corporate agenda. Stay up-to-date with global developments by reading our Indirect Tax Briefing. | 20110801August 2011 |
| Driving improved supply chain results | How will you improve your supply chain results in this competitive market? Read more on how to get the best results in emerging and developed markets. | 20110701July 2011 |
| Seizing opportunity in Global Compliance & Reporting | Don’t allow your GCR processes to perform at yesterday’s standards. Our survey results show the need to formalize plans for improving GCR for the future. | 20110701July 2011 |
| Europe’s CCCTB proposals | The proposal for a Common Consolidated Corporate Tax Base (CCCTB) will create winners and losers. Access all our materials related to the CCCTB proposals. | 20110701July 2011 |
| VAT and GST: Can indirect tax compliance be easier? | Take a look at how companies are confronting indirect tax management and the nine leading practices they follow. | 20110601June 2011 |
| Monitoring tax policy and enforcement shifts | In an exclusive interview from our Tax Policy & Controversy Quarterly Briefing, learn of developments of tax administration in the Americas from CIAT leader Márcio Verdi. | 20110601June 2011 |
| VAT and GST: managing the mutinational burden | Take a look at how companies are confronting indirect tax including value added tax and goods and services tax, and the nine leading practices they follow. | 20110501May 2011 |
| US healthcare reform: One year in | A political update on the one-year anniversary of the Patient Protection and Affordable Care Act. | 20110401April 2011 |
| Transfer pricing information at your fingertips | Quickly identify the transfer pricing rules, practices and approaches adopted by more than 55 countries and territories in our Transfer Pricing Reference Guide for 2011. | 20110401April 2011 |
| Tax Policy and Controversy Quarterly Briefing - April 2011 | Learn about the development of leading tax administrations in the Inter-American region from our interview with Márcio Verdi. | 20110401April 2011 |
| Indirect taxes: are you up to speed? | Governments are increasingly using indirect taxes to finance politically urgent priorities. Our Indirect Tax Briefing summarizes the changes ahead in VAT, GST and indirect taxes. | 20110401April 2011 |
| Indirect tax in 2011 | Provides a detailed overview of the changes ahead in VAT, GST and other indirect taxes. | 20110401April 2011 |
| Indirect Tax Briefing - April 2011 | Our new thought leadership, Indirect Tax in 2011, provides a detailed overview of the changes ahead in VAT, GST and other indirect taxes. | 20110401April 2011 |
| Alternative Dispute Resolution: a new chapter emerges | Here we set out the different types of ADR tools available in both the pre- and post-filing environments, and discuss the factors to consider. | 20110401April 2011 |
| Why transfer pricing still dominates tax agenda | Read about six major trends in transfer pricing. Also, what are four things multinationals should do in regards to transfer pricing? Learn more from our recent survey. | 20110301March 2011 |
| Tax policy in 2011 | What distinguishes the tax policies of geographic regions? We have developed a suite of policy reports – covering the Americas, Asia-Pacific and Europe, Middle East, India and Africa. | 20110301March 2011 |
| European Commission publishes final Common Consolidated Corporate Tax Base (CCCTB) proposals | The proposal for a Common Consolidated Corporate Tax Base (CCCTB) will create winners and losers. Access all our materials related to the CCCTB proposals. | 20110301March 2011 |
| 2011 EMEIA tax policy outlook | What distinguishes tax policies of geographic regions? To help answer this questions, we developed a tax policy outlook reports for the Middle East, India and Africa. | 20110301March 2011 |
| 2011 Asia Pacific tax policy outlook | What distinguishes tax policies of geographic regions? To help answer this questions, we developed a tax policy outlook reports for Asia-Pacific. | 20110301March 2011 |
| 2011 Americas tax policy outlook | What distinguishes tax policies of geographic regions? To help answer this questions, we developed a tax policy outlook reports for the Americas. | 20110301March 2011 |
| 2010 Global transfer pricing survey | Read about six major trends in transfer pricing that keep tax professionals up at night. | 20110301March 2011 |
| United States 2011 tax legislative outlook | While much of 2010 was shaped by a difficult political and economic climate, 2011 is showing signs of positive economic growth, and policymakers seem encouraged to work together. | 20110201February 2011 |
| Tax Policy and Controversy Quarterly Briefing - February 2011 | No matter what your industry or location, tax policy and tax enforcement affect you. This issue explains emerging tax issues on a global and local scale, from China to the US and everywhere in between. | 20110201February 2011 |
| Deficit Reduction Watch: CBO's large deficit projections set the stage for tax and entitlement reform debate | Find out in Deficit Reduction Watch how large budget deficits are putting pressure on tax expenditures. As discussions move forward, companies should be alert and participate early in the process. | 20110201February 2011 |
| Tax administration without borders | What should businesses do to reduce the risk of controversy? Find out more in Tax administration without borders. | 20110101January 2011 |
| Resolving disputes: ways to reach certainty, sooner | Tax enforcement is on the rise; learn about the pre- and post-filing dispute resolution tools and processes now on offer from tax administrations around the world. | 20110101January 2011 |
| Wealth under the spotlight: Tax administration without borders | The financial crisis has shifted the way tax administrations engage with high net worth individuals. Here we outline the changes and how to adjust to rapidly changing taxation policies. | 20101201December 2010 |
| Indirect Tax Briefing - April 2011 | Our new thought leadership, Indirect Tax in 2011, provides a detailed overview of the changes ahead in VAT, GST and other indirect taxes. | 20110401April 2011 |
| Global tax trends: raising and investing capital | We asked tax directors at 130 of the world's largest companies for their views on the tax issues surrounding transactions. | 20101101November 2010 |
| Research incentives in the new tax landscape | R&D is a long acknowledged driver of economic prosperity and competitiveness, and the prevalent view is that more private investment in R&D will yield significant social benefit. | 20100901September 2010 |
| Title | Summary | Date |
|---|---|---|
| IRS publishes legal advice applying economic substance doctrine | The legal advice will disregard securities lending transactions used to avoid withholding taxes. Learn more. | 2012121111 December 2012 |
| Treasury and IRS 2012-2013 Priority Guidance Plan | In November 2012, Treasury and the IRS released this Plan, which provides an overview of issues that they intend to address over the period ending 30 June 2012. | 2012112929 November 2012 |
| REIT’s Subpart F and PFIC inclusions | In Private Letter Ruling 201246013, the Service ruled that a REIT’s Subpart F inclusions and PFIC inclusions constitute income for purposes of the 95% income test. | 2012112727 November 2012 |
| Treasury issues Model 2 FATCA Intergovernmental Agreement | The release of Model 2 IGA has been anticipated for some time and is an important part of the developing body of guidance on FATCA. | 2012111818 November 2012 |
| IRS Chief Counsel Advice address criteria for Forms W-8 | The CCA contains language by the IRS addressing the benchmarks that withholding agents should apply when accepting Forms W-8 received by fax or in PDF | 201211088 November 2012 |
| Washington Dispatch: November 2012 | Now that elections have ended, Congress and the President could go in several directions with regard to the fiscal cliff before year end. Learn more | 201211296 November 2012 |
| OECD revises Commentary to Model Tax Convention draft | The OECD Model and its Commentary influence the interpretation of tax treaties in many countries, although the US Model Treaty is accorded greater weight. Learn more. | 201211022 November 2012 |
| Washington Dispatch: October 2012 | The IRS and Treasury on 24 October 2012 issued the latest in a series of guidance related to FATCA. How it will impact your business? | 201211011 November 2012 |
| Treasury extends FATCA due diligence timelines | On 24 October 2012, Treasury and the IRS issued Announcement 2012-42, the latest guidance items related to the Foreign Account Tax Compliance Act. Learn more. | 2012102424 October 2012 |
| Hybrid instrument properly characterized as equity | The US Tax Court recently held that “advance agreements” by domestic subsidiaries of PepsiCo, Inc., and by PepsiCo Puerto Rico., Inc., were properly characterized as equity. | 201210033 October 2012 |
| Washington Dispatch: September 2012 | In September 2012, the US Treasury Department signed a bilateral agreement with the UK to implement the information reporting and withholding tax requirements of FATCA. | 2012093030 September 2012 |
| Tax considerations in cloud computing: global survey | Examining 11 countries in which cloud service providers most often conduct their operations, we provide insights into their tax environment and their operations. | 2012092424 September 2012 |
| Washington Dispatch 2012 Year-in-Review | Inside, we have compiled significant US international tax developments and guidance issued during the period of January through September 2012 on inbound and outbound taxation. | 2012092020 September 2012 |
| US and UK sign agreement on international tax compliance | On 14 September 2012, the Treasury Department announced signing an agreement with the UK to implement information reporting and withholding tax requirements of the FATCA. | 2012091717 September 2012 |
| Temporary regulations extend current treatment for NPCs (and ELIs) under Section 871(m) | On 31 August 2012, the Treasury Department and the Internal Revenue Service released temporary regulations (TD 9572) extending the date for applying the interim statutory definition of specified notional principal contacts (NPCs) to payments under Section 871(m). | 2012091212 September 2012 |
| IRS issues final, temporary, and proposed regulations on integrated hedging transactions of qualifying debt | On 6 September 2012, the Treasury Department and the Internal Revenue Service published final and temporary regulations (T.D. 9598) and proposed regulations (REG-138489-09) under Section 988(d) that address what the government viewed as a troublesome result arising from certain integrated transactions that involve a foreign currency denominated debt instrument and two or more associated hedging transactions. | 2012091010 September 2012 |
| Ninth Circuit affirms Tax Court: Transfer of notes for 90% of value is sale, not loan | In Kurt Sollberger v. Comm’r., the Court of Appeals for the Ninth Circuit upheld a Tax Court ruling (Sollberger v. Comm’r., T.C. Memo 2011-78) that the transfer of floating rate notes in exchange for cash was a sale, not a loan, for tax purposes. | 2012082424 August 2012 |
| Treasury adds Iraq to the list of current international boycott countries | On 17 August 2012, the Treasury Department published a notice in the Federal Register, updating the list of countries that require or may require participation in, or cooperation with, an international boycott (boycott countries) within the meaning of Section 999(b)(3) of the Internal Revenue Code. (17 Fed. Reg. 49864). The most noteworthy change to the list recently released is the addition of Iraq. | 2012082424 August 2012 |
| Washington Dispatch (Volume 16, Issue 8) | In this issue... 1) Congress moves tax legislation before adjourning for August recess; 2) US, Canada agree on business profits interpretation in PE context IRS news; 3) LB&I directive issued on partial worthlessness deductions taken by insurance companies; 4) Treasury official provides guidance update. | 2012082424 August 2012 |
| IRS issues LB&I directive on partial worthlessness deductions under Section 166(a)(2) taken by insurance companies | The Service has issued a Large Business & International (LB&I) Industry Director Directive (an IDD) addressing partial worthlessness deductions under Section 166(a)(2) taken by insurance companies for eligible loans | 201208077 August 2012 |
| FATCA Model Intergovernmental Agreement released - US | On 26 July 2012, the US Treasury Department issued the first model for an Intergovernmental Agreement (IGA) for complying with the Foreign Account Tax Compliance Act (FATCA) provisions. | 2012073030 July 2012 |
| IRS Notice 2012-39 announces regulations to be issued under Section 367(d) | The Treasury Department and IRS announce their intention to issue regulations that would require immediate income recognition in connection with certain outbound transfers of intangible property. | 2012072020 July 2012 |
| Instruments issued by a subsidiary to its UK parent were debt | The Tax Court held that notes given by a US company to its ultimate UK parent in exchange for its stock constituted debt. | 201207022 July 2012 |
| Service changes ITIN application procedures—Original identity documents or copies certified by issuing agency must be submitted to IRS | On 22 June 2012, the IRS in a news release announced interim changes to the Individual Taxpayer Identification Numbers (ITIN) application procedures. The changes, effective immediately, require applications to be accompanied by original supporting documentation or copies of original documents certified by the issuing agency (notarized copies will no longer suffice). | 201207022 July 2012 |
| Washington Dispatch (Volume 16 Issue 7) | In this issue...1) Congress reviews tax reform options; territorial tax system enters presidential politics. 2) FATCA Model Intergovernmental Agreement released. 3) Notice 2012-39 announces regulations to be issued under Section 367(d) affecting certain outbound transfers of intangible property in asset reorganizations... | 201207011 July 2012 |
| Treasury issues final and proposed regulations clarifying prior guidance on ODLS and the coordination with OFL and SSL provisions | On 21 June 2012, Treasury and the IRS issued final regulations (TD 9595) (final regulations) and proposed regulations (REG-134935-11) (proposed regulations) under Sections 904(f) and 904(g), relating to the recapture (and coordination) of overall foreign loss (OFL) accounts and overall domestic loss (ODL) accounts. | 2012062828 June 2012 |
| HP’s investment in foreign entity characterized as debt: foreign tax credits and capital loss disallowed | In Hewlett-Packard Corp., et al. v. Commissioner, the Tax Court ruled that Hewlett-Packard’s (HP) investment in a foreign entity was “more appropriately characterized” as debt for federal income tax purposes. Accordingly, the Tax Court disallowed the foreign tax credit under Section 902 that resulted from HP’s receipt of dividends on such investment. | 2012062828 June 2012 |
| United States issues joint statements with Japan and Switzerland on intergovernmental cooperation to facilitate FATCA compliance | On 21 June 2012, the US Treasury Department issued two joint statements on intergovernmental cooperation to facilitate compliance under the Foreign Account Tax Compliance Act (FATCA) provisions, one with the government of Japan and one with the government of Switzerland. | 2012062222 June 2012 |
| Fifth Circuit holds UK “windfall tax” is creditable | In Entergy Corp. v. Commissioner, the US Court of Appeals for the Fifth Circuit (Fifth Circuit) affirmed a US Tax Court decision holding that the UK “windfall tax,” which was computed on the basis of a formula whose primary variable referenced profits earned over multiple years, was a creditable income tax for purposes of Section 901 (i.e., a creditable tax). | 20120613June 2012 |
| New Section 7874 regulations establish brightline rule for substantial business activities test | On 7 June 2012, Treasury and the IRS issued final regulations (TD 9591) and proposed and temporary regulations (TD 9592) on whether a foreign corporation is treated as a surrogate foreign corporation under Section 7874. | 2012061313 June 2012 |
| US customs adopts new policy accepting transfer pricing adjustments | US Customs and Border Protection (CBP) has adopted a policy first proposed in September, which will accept transfer pricing adjustments, provided that specified conditions are met. The new policy broadens CBP’s interpretation of what constitutes a formula for purposes of using “transaction value.” | 201206055 June 2012 |
| Washington Dispatch Volume 16, Issue 6 | In this issue: Tax extender provisions under review; House to vote on Bush tax cuts in July. United States issues joint statements with Japan and Switzerland on intergovernmental cooperation to facilitate FATCA compliance. New Section 7874 regulations establish bright-line rule for substantial business activities test. | 201206011 June 2012 |
| Refund claim based on a self-initiated Section 482 adjustment dismissed by US Claims Court | Intersport Fashions West Inc.’s (Intersport) suit seeking a refund for a self-initiated Section 482 adjustment has been dismissed by the US Court of Federal Claims. | 2012053131 May 2012 |
| Hyperinflationary list for 2012 available | The Section 985 regulations require entities operating in countries with a hyperinflationary currency to use the US dollar as their functional currency and to apply the dollar approximate separate transactions method of accounting (DASTM). | 2012052323 May 2012 |
| New regulations modify definition of US property for US shareholders in CFCs that make certain upfront swap payments | The IRS has issued regulations providing that obligations of US persons arising from upfront payments made by CFCs under certain cleared contracts do not constitute US property under IRC Section 956(a). | 2012051717 May 2012 |
| Changes to Canada's SR&ED filing deadline for partnerships discussed | The Canada Revenue Agency recently announced in its 2011 "Guide for the T5013 Partnership Information Return" that when a partnership is required to file form T5013 and has incurred SR&ED expenditures, it must file Form T661, "Scientific Research and Experimental Development (SR&ED) Expenditures Claim," no later than 12 months after the due date of its T5013. | 2012051717 May 2012 |
| Washington Dispatch Volume 16, Issue 5 | In this issue: Obama Administration, House Republicans stake positions on tax reform, 2001/2003 tax cuts, and debt limit IRS news. New tangible property regulations have implications for US MNCs. IRS finalizes rules on application of Section 1248(a) to gain recognized under Sections 301(c)(3), 302(a) and 331(a). IRS modifies definition of US property for US shareholders in CFCs that make certain upfront swap payments. | 201205011 May 2012 |
| Transfer pricing - El Salvador | On 23 March 2012, the Dirección General de Impuestos Internos (“DGII”) issued Administrative Guideline No. DG-001/2012, intended to provide general guidance to taxpayers on the tax treatment of related party transactions or transactions with entities domiciled in tax havens jurisdictions. | 201205011 May 2012 |
| Transfer pricing - El Salvador | On 23 March 2012, the Dirección General de Impuestos Internos (“DGII”) issued Administrative Guideline No. DG-001/2012, intended to provide general guidance to taxpayers on the tax treatment of related party transactions or transactions with entities domiciled in tax havens jurisdictions. | 201205011 May 2012 |
| Transfer pricing - El Salvador | On 23 March 2012, the Dirección General de Impuestos Internos (“DGII”) issued Administrative Guideline No. DG-001/2012, intended to provide general guidance to taxpayers on the tax treatment of related party transactions or transactions with entities domiciled in tax havens jurisdictions. | 201205011 May 2012 |
| Transfer pricing - El Salvador | On 23 March 2012, the Dirección General de Impuestos Internos (“DGII”) issued Administrative Guideline No. DG-001/2012, intended to provide general guidance to taxpayers on the tax treatment of related party transactions or transactions with entities domiciled in tax havens jurisdictions. | 201205011 May 2012 |
| Colombian tax developments of interest to oil, gas and mining industries highlighted | In its May 2012 Oil & Mining Bulletin, Ernst & Young Colombia highlights recent Colombian tax developments of interest to the oil, gas, and mining industries. The alert summarizes these discussions in both English and Spanish. | 201205011 May 2012 |
| Foreign Desk: Argentina releases details of proposed tax reform "Anti-Evasion Plan III" | The Argentine Executive Power has proposed a tax reform plan that would significantly change the country's Income Tax Law, Tax Procedural Law and other tax regulations. This alert summarizes the potential impact of this plan. | 2012043030 April 2012 |
| IRS finalizes regulations on application of Section 1248(a) to gain recognized under Sections 301(c)(3), 302(a) and 331(a) | In TD 9585, the Treasury Department finalized, without substantive change, regulations on the application of Section 1248(a) to gain recognized under Sections 301(c)(3), 302(a) and 331(a) on the receipt of a distribution of property with respect to stock in certain foreign corporations. | 2012042727 April 2012 |
| New tangible property regulations have implications for US multinationals | New rules issued by the IRS apply not only for purposes of computing taxable income of US taxpayers, but also for purposes of computing earnings and profits of US-owned foreign corporations. | 2012042323 April 2012 |
| Annual APA report for 2011 | The IRS issued the thirteenth congressionally-mandated, annual Advance Pricing Agreement (APA) report on 2 April 2012, in Announcement 2012-13. | 201204055 April 2012 |
| APAs | IRS issues thirteenth annual APA report for 2011. | 201204055 April 2012 |
| Miscellaneous | Washington Dispatch. | 201204011 April 2012 |
| Miscellaneous | Global Dispatch. | 201204011 April 2012 |
| Transfer pricing - Hong Kong | On 29 March 2012, the HKIRD released a finalized version of DIPN 48, responding in detail to the various points raised during the consultation process. Clarifications were made in the finalized version of DIPN 48. This tax alert includes the key clarifications and changes of DIPN 48. | 2012032929 March 2012 |
| Tax News: Investing in the US | Please read the March issue for more information. | 2012032929 March 2012 |
| Transfer pricing - Guatemala | Guatemala issued Transfer Pricing rules included in the Tax Legislation Update Law (TLUL) of the Congress Decree 10 - 2012. The TLUL introduces new transfer pricing rules applicable to individuals or business entities that have related party transactions. | 2012031616 March 2012 |
| Transfer pricing - India | In a letter dated 12 March 2012 addressed to the United Nations (UN), the Indian Government condemns the use of the OECD Transfer Pricing Guidelines by the UN. Instead, it appears the Indian Government proposes the UN develop a manual on transfer pricing that departs from the OECD Transfer Pricing Guidelines to the benefit of the developing countries. | 2012031616 March 2012 |
| Transfer pricing - India | The Indian Union Budget for 2012-13 containing the tax proposals of the Government was presented by the Finance Minister to the Parliament on 16 March, 2012. | 2012031616 March 2012 |
| Capital Markets | IRS issues guidance on repeal of rules allowing bearer bonds to be assured abroad. | 2012031414 March 2012 |
| Transfer pricing - Jaoan | Following a period of public consultation, the Japanese National Tax Agency (NTA) has released revised guidance to examiners regarding the application of transfer pricing legislation (Administrative Guidelines). | 201203022 March 2012 |
| Legislation | Senator Enzi introduces an international tax reform bill. | 201203011 March 2012 |
| Miscellaneous | Washington Dispatch. | 201203011 March 2012 |
| Miscellaneous | Global Dispatch. | 201203011 March 2012 |
| Tax News: Investing in the US | President Obama delivers State of the Union, details emerge on "insourcing" proposal. | 20120101January 2012 |
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