In an International Practice Unit (IPU), the IRS outlined the steps its auditors should take when issuing a recordkeeping and reporting summons to a U.S. corporation that is 25% owned by a foreign shareholder.
The tax agency also elaborated on what to do when the U.S. corporation doesn’t substantially comply with the summons.
Moscow enacted a law ordering certain foreign companies engaged in online sales of electronic content in Russia to pay the value-added tax (VAT). (Foreign providers of electronically supplied services.)
The law, informally known as the “Google Tax,” stipulates the introduction of an 18% VAT for foreign companies providing services to Russians in electronic form. Foreign companies will need to register on the Russian tax service’s special electronic index and pay taxes on an equal footing with Russian companies operating in the same market segment. Before the law was passed by the Russian Parliament, no VAT was imposed on electronic services supplied by foreign companies. This tax break wasn’t available to Russian companies.
If a foreign company has a Russian division or a contractor in the country, it will be responsible for paying the tax irrespective of whether it has an appropriate agreement with foreign corporations or not.
If the buyer carries out activities on the territory of the Russian Federation and acquires the “services in electronic form,” the place of supply of these services is the territory of the Russian Federation. Delivery of physical goods ordered over the internet is not subject to the VAT. (more…)
Facebook may have understated the value of intangible property transferred to its Irish holding company by “billions of dollars.” That’s according to a petition the U.S. Justice Department and the IRS filed in the U.S. District Court for the Northern District of California.
The petition was filed to enforce certain summonses served on the social media company in connection with outstanding information requested as part of an IRS audit. It makes the following claims: (more…)
San Jose, CA August 16, 2016 — we are pleased to announce that Jyothi Chillara and Naila Sharifova of Abbott, Stringham & Lynch have successfully earned the IBFD-AG Advanced Professional Certificate in International Corporate Taxation. Jointly created by Allinial Global and IBFD, one of the world’s foremost authorities on international taxation, this rigorous program allows participants to differentiate themselves by becoming certified experts in international taxation.
On their way to certification, program participants earn 100 CPE credits and engage in a combination of self-study courses and live webcasts, followed by a final three-day training event. Course materials focus on three central components: fundamentals of international taxation, corporate international tax structuring, and treaty and transfer pricing aspects of international tax planning. In order to complete the certification process, participants must pass an assessment during each stage of the program, as well as a two-hour final exam. (more…)
International value-added tax guidelines from the OECD were endorsed by 104 countries. The move is a step toward ensuring that consumption taxes are paid in the jurisdictions where products are consumed, particularly when the sales are online. This article looks at the details of the guidelines.
As if individuals and entities with foreign investments do not have enough reporting to do already, they are now required by the Bureau of Economic Analysis under the US Department of Commerce to fill out mandatory surveys about their foreign affiliates. The key here is that it is mandatory and the only incentive for filling it out is not to incur a penalty that may range from $2,500 to $25,000. Looks more like a stick to me than a carrot…
By Guest Blogger: Rob Trammell, ASL Principal
The IRS recently released a “Roadmap for Transfer Pricing Auditors.” This roadmap lays out IRS policy related to transfer pricing issues, and provides auditors with tools and detailed procedures for how to work a case.