United States Tax News

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U.S. 2020-2021 Priority Guidance Plan Issued

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U.S. Tax Court Sustains IRS's Transfer Pricing Reallocations Under Comparable Profits Method

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US and Mexico renew competent authority agreement on unilateral APAs for maquiladoras

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U.S. IRS Announce Renewal of Competent Authority Agreement on Maquiladoras

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UK proposes to amend hybrid and other mismatches regime – implications for US multinationals

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U.S. IRS and Treasury Issue Corrections to Regulations on Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income

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U.S. IRS and Treasury Issue Final and Temporary Regulations and Proposed Regulations on Foreign Tax Credits

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The EU Puts Countermeasures in Place Against U.S. Exports

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U.S. IRS Releases Guidance Regarding Deductibility of Payments by Partnerships and S Corporations for State and Local Income Taxes

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U.S. IRS and Treasury Consulting on Forms Used by Business Entity Taxpayers

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Tax Treaty between Croatia and the U.S. Under Negotiation

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U.S. IRS and Treasury Issue Final and Temporary Regulations on Gain or Loss of Foreign Persons from Sale or Exchange of Partnerships

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US: Proposed regulations would revamp creditability rules for foreign income taxes

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Joint Statement between the U.S. and France Published on the Spontaneous Exchange of CbC Reports for 2019

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U.S. Signs CbC Exchange Agreement with Germany

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U.S. IRS and Treasury Issue Corrections to Regulations on Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income

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US IRS announces plans to limit the use of “telescoping” in APA and MAP cases

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Digital Companies Continue to Pass on Cost of Taxes on Digital Services to Consumers

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U.S. IRS and Treasury Issue Corrections to Regulations on Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income

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U.S. IRS and Treasury Final Regulations on Consolidated Net Operating Losses Published

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U.S. IRS Provides Tax Inflation Adjustments for Tax Year 2021

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European Commission Announces Green Light for EU to Impose Duties on U.S. Imports

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US IRS concludes anti-abuse rule under Section 704(c) triggered in asset contribution to foreign partnership

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US: Final regulations under Section 1446(f) set forth rules on withholding on transfers of partnership interests

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U.S. IRS Issues Announcement on Termination of Shipping Agreement with Hong Kong

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Spanish Supreme Court confirms case law on limits to dynamic interpretation of tax treaties

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US IRS confirms that some modifications to debt instruments and other contracts to reflect LIBOR discontinuation will not result in a deemed taxable exchange

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US: Calendar year 2019 FBARs extended to 31 October

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U.S. IRS Issues Revenue Procedure on Transition from LIBOR and IBOR to Alternative Reference Rates

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US: Additional final regulations provide foreign tax credit guidance

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