The recent agreement on a global minimum tax, and other changes to tax rules around the world, have called into question the future of tax competition. Each year, The Tax Foundation puts out its International Tax Competitiveness Index. The Index seeks to measure the extent to which a countries’ tax system adheres to important aspects…
Transfer pricing may be one of the most talked-about and least understood tax topics right now. The underlying concept is simple: it’s the method for pricing transactions between related parties. But what qualifies as “related parties” and how those transactions are valued have become increasingly complicated in a more global and more digital world. Companies…
Today, FinCEN moved to again clarify questions surrounding the due date for filing Reports of Foreign Bank and Financial Accounts (FBARs). The FBAR requirements (31 CFR 103.24) are part of the Banking Secrecy Act (BSA). Under the rules, each “US person” with an interest in, signature or other authority over, one or more bank, securities,…
In 2014, the European Commission announced that it would formally investigate the tax structures and practices of a handful of companies including Apple (Ireland), Fiat Finance and Trade (Luxembourg), and Starbucks (Netherlands). The inquiry followed months of promises by world leaders to ensure tax compliance after not-so-shocking revelations that multinational companies were engaging in controversial…
Many years ago, a crack unit of specialists from Big Four audit firms and boutique consultancy firms – were working on the mean streets of Broadway to South Street on the East River in Lower Manhattan. These men promptly escaped from the financial district to the nation’s capital. Today, they are wanted by the government….
Follows are the prepared remarks of IRS Commissioner Doug Shulman before the 23rd Annual Institute on Current Issues in International Taxation, Washington, DC. I rarely use the “read more” feature on the blog but I did in this case because, well, the remarks are quite long. Worth the read, however. Shulman even tries his hand…