The IRS recently issued an International Practice Unit (IPU) that outlines for its examiners the general rules for determining the source of fixed, determinable, annual or periodical (FDAP) income.
The tax agency stated that source determination is “critically important,” as the U.S. only has jurisdiction to tax FDAP income sourced to the U.S. A withholding agent that is unable to establish the source of FDAP income would generally be required to presume the income is U.S. sourced and obliged to withhold tax. (more…)
By Guest Writer: Andy Dawnbarn, Wilkins Kennedy LLP
Andy Dawbarn is partner at Wilkins Kennedy (WK) in the UK. WK is one of the largest accounting and consulting firms in the UK and a new member of Allinial Global. Andy specializes in Value Added Taxes (VAT) having spent over 30 years in VAT, including HM Customs and Excise.
As Britain is left waiting to see what the future holds as an independent nation, many businesses will be asking questions about what to expect following the Brexit result and key timings as to when those changes will be taking place. VAT is one area where the UK could see more significant changes after leaving the EU and out of all the taxes is likely to be the most affected. (more…)
All 28 European Union (EU) member states reached political agreement on the European Commission’s (EC’s) Anti-Tax Avoidance Directive designed to combat multinational corporation tax avoidance.
During negotiations, some amendments were made to the proposal, including the deletion of the controversial “switch-over clause” to prevent double nontaxation of certain income.
The approval came before Britons voted to leave the EU, a move that has significant tax implications (see sidebar below).
The final Anti-Tax Avoidance Directive includes the following: (more…)