KPMG’s Week in Tax: 14-18 September

KPMG’s Week in Tax: 14-18 September

The OECD is expected to begin releasing its final findings under the base erosion and profit shifting (BEPS) project within coming weeks. This week, there were developments reflecting one of the BEPS proposals—country-by-country (CbC) reporting.


Related content

  • Netherlands: The tax plan 2016, presented this week, includes new proposals for additional transfer pricing documentation—specifically, CbC reporting.
  • Australia: A bill was presented to Parliament that, if enacted, would require CbC reporting. 

Read more at TaxNewsFlash-BEPS

United States

The IRS this week announced a plan for reorganization of the Large Business and International (LB&I) division.

The Tax Section of the American Bar Association meets at the end of this week in Chicago, and as in prior years, the IRS and Treasury Department released guidance items for presentation and discussion at the ABA Tax Section’s meeting.  This year’s guidance includes the following:

  • Rev. Proc. 2015-48: Guidelines for application of the retroactive 50% first-year “bonus” depreciation
  • Regulations: Treatment of dividend equivalents from sources within the United States paid to nonresident alien individuals and foreign corporations
  • Regulations: Temporary regulations to clarify the arm’s length standard and the best method rule under Code section 482 and, by cross-reference, proposed regulations relating to the transfer of property—including foreign goodwill and going-concern value—to foreign corporations in nonrecognition transactions under section 367
  • Proposed regulations: “Contemporaneous written acknowledgement” for charitable contribution deductions, would provide voluntary system for donee reporting
  • Final regulations: Revised examples illustrating controlled group rules for regulated investment companies (RICs)
  • Notice 2015-68: Future regulations to address information reporting for health insurance coverage
  • Notice 2015-63: Per diem rates, substantiation of employee lodging, meals, incidentals (2015-2016)
  • Notice 2015-59, Rev. Proc. 2015-43: Guidance under section 355 and distributions to RICs, REITs

Read more at TaxNewsFlash-United States

FATCA developments

  • Cyprus: A decree published in the official gazette provides rules for financial institutions in Cyprus to comply with the IGA with the United States.

Read more at TaxNewsFlash-FATCA

International tax news

  • Mexico: An economic package presented to the Mexican Congress includes certain proposals for changes to prior tax reform. Read more at TaxNewsFlash-Americas
  • China: World Trade Organization’s protocol of the trade facilitation agreement is ratified. Read more at TaxNewsFlash-Asia Pacific
  • Netherlands: The Dutch Cabinet presented the 2016 tax plan to the Lower House. Read more at TaxNewsFlash-Europe
  • France: Rules concerning the tax treatment of profits transferred abroad by French taxpayers, to allow for the repatriation of these funds without additional tax—and in particular, without application of withholding tax, with transfer pricing re-assessments. Read more at TaxNewsFlash-Transfer Pricing

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

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