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Eaton v. IRS: Tax Court determines IRS abused its discretion in cancelling two APAs

The Tax Court in Eaton Corporation and Subsidiaries v. Commissioner, T.C. Memo, 2017-147 determined that the IRS abused its discretion in cancelling two unilateral advanced pricing agreements (APAs) covering the transfer of...more

OECD releases new discussion draft on transfer pricing documentation – a template for multinational reporting of global business...

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released its proposed updated guidelines on transfer pricing documentation, including country-by-country reporting (CbC),...more

IRS proposes changes to Competent Authority and APA procedures: comments requested by 3/20/2014

The IRS has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the Mutual Agreement Procedures (MAP) and other provisions of US...more

International Tax News - December 2013

CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund industry...more

OECD issues White Paper on transfer pricing documentation: new requirements for multinationals coming in 2014?

The OECD has issued the “White Paper on Transfer Pricing Documentation” outlining ideas for new global standards for the annual transfer pricing documentation exercise required by more than 60 countries. ...more

International Tax News - July 2013

OECD RELEASES “BEPS” ACTION PLAN – A SWEEPING INTERNATIONAL TAX EFFORT TO COMBAT BASE EROSION AND PROFIT SHIFTING - The OECD’s Committee on Fiscal Affairs has published its Action Plan to address Base Erosion and...more

OECD releases “BEPS” Action Plan – a sweeping international tax effort to combat base erosion and profit shifting

The OECD’s Committee on Fiscal Affairs (CFA) has published its Action Plan to address Base Erosion and Profit Shifting (BEPS). This sweeping international effort aims to combat a comprehensive range of international tax...more

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