In response to EU investigations into tax breaks for US-based companies, four US Senators have asked the Obama administration to consider retaliatory double taxes on EU countries. The request amplifies the brewing conflict between US and EU officials over investigations that are questioning tax deals involving e.g. Apple Inc….
On December 23, 2015, the IRS issued a proposal on implementation of country-by-country reporting in the United States. The proposed regulations (REG-109822-15) describe a new requirement for certain US persons that are the ultimate parent entity of an MNE group to file an annual report if the US MNE…
The US Joint Committee on Taxation (JCT) has provided an overview of its findings and recommendations regarding implementation of measures proposed by the OECD/G20 BEPS Project with regards to the US tax policy. The document was prepared by the JCT staff to provide background information for public hearing held…