Luis Ramirez, Principal
ASL International Group
U.S. taxpayers with maquiladora operations in Mexico won’t be exposed to double taxation if they enter into a unilateral advance pricing agreement (APA) with Mexico’s tax agency under terms that were negotiated by the U.S. and Mexico.
The companies would have to reach the agreements with the Large Taxpayer Division of Mexico’s tax agency, the Servicio de Administración Tributaria (SAT). (more…)
Ireland’s Department of Finance outlined its key arguments to appeal the European Commission’s (EC’s) ruling that it had breached European Union (EU) state aid rules in its tax deal with Apple.
Arguments for the appeal
In a statement, Irish Finance Minister Michael Noonan outlined several arguments for the appeal.
First, he said, Ireland didn’t provide favorable treatment to Apple. The Chairman of Ireland’s Revenue Commissioners has stated that:
- There was no departure from the applicable Irish tax law,
- There was no preference shown in applying the law, and
- The full tax due was paid in accordance with the law.
(more…)
On June 24th, Ways and Committee Chairman Brady released a blueprint for tax reform labeled as “A Better Way for Tax Reform.” The agenda is a result of a committee formed to study and develop policy recommendations under Speaker Ryan’s direction to create new jobs, grow the economy, raise wages by reducing tax rates, and to make the code simpler and fairer.
The result is a blueprint of the current House’s view of tax reform. The intent of the blueprint is to be ready for legislative action in 2017. Key provisions of the reform blueprint include: (more…)
By Sylvia Chan, Tax Senior
There has been much discussion about restructuring the California Tax System. Currently, California relies significantly on personal income tax collection to fund its state expenditures. Tax revenue based on personal income relies heavily on the unpredictability of capital gains which makes it impossible to forecast the state’s future revenue. This puts California in a very vulnerable situation should the stock market collapse, creating an abrupt shortfall in the State budget. Most people would agree that the California tax system is outdated, unfair, unreliable and long overdue for tax reform. (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…)
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…)
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.
Before Brexit
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…)