KPMG’s Week in Tax: August 17-21

KPMG’s Week in Tax: August 17-21

U.S. tax developments reported this week include the following:


Related content

  • The Insurance Branch of IRS Chief Counsel-FIP publicly released a legal memorandum concluding that 10-year excess loss policies issued by a captive insurance company to affiliated (brother-sister) companies did not qualify as insurance for federal income tax purposes.
  • An IRS release provided a reminder to truckers and owners of heavy highway vehicles that, for most, the federal highway use tax return is due Monday, August 31, 2015.

Read more at TaxNewsFlash-United States

  • KPMG explanations of two revenue procedures, issued in earlier in August 2015, that provide guidance for requesting competent authority (CA) assistance, and concerning the process for requesting and obtaining advance pricing agreements (APAs) and the administration of executed APAs. 

Read TaxNewsFlash-Transfer Pricing

  • USTR announced that petitions seeking duty-free treatment of imports under the Generalized System of Preferences (GSP) program or seeking GSP status for certain beneficiary developing countries are due by October 16, 2015.

Read TaxNewsFlash-Trade & Customs

FATCA developments

  • Barbados; St. Vincent and the Grenadines: Intergovernmental agreements (IGAs) signed with the United States, following the Model 1 IGA for implementing the FATCA regime. 
  • US: The Treasury Department posted an updated notification of “more favorable terms” concerning “certain alternative procedures” under the Model 1 IGA.
  • US: A new FAQ on form and documentary evidence received by facsimile or email as well as updated IDES user guide and XML schema were released.

Read TaxNewsFlash-FATCA

International tax news

  • Canada: SLFIs that recently filed their 2014 indirect tax returns need to review their processes to improve efficiency and reduce risks for their 2015 returns. It is essential that these systems and processes not only meet operational and business requirements, but also help meet GST/HST and QST reporting obligations efficiently and effectively. Read TaxNewsFlash-Americas
  • Korea: A matter pending before an appellate court in South Korea could allow refunds of certain amounts of tax withheld on payments distributed to Luxembourg SICAVs. If the appeals are ultimately decided in favor of the SICAVs, they could be entitled to a refund of the difference between the withholding tax paid at a “standard” rate and the treaty-related rate of withholding tax. Read TaxNewsFlash-Asia Pacific
  • Finland: The Helsinki administrative court granted a refund of taxes to a German real estate investment fund. The decision may also benefit non-UCITS funds and allow them a refund of taxes based on EU law. Read TaxNewsFlash-Europe


Read these and other items reported this week at the TaxNewsFlash United States and Global websites.

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