News & Analysis as of

Foreign Account Tax Compliance Act Transfer Pricing

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +
The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts.  less -
Eversheds Sutherland (US) LLP

LB&I announces new campaigns – Related-party service companies, offshore private banking and loose-filed Forms 5471

On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Troutman Pepper

International Tax Grows Up: The Tax Section at 75, Subpart F at 53, and the Foreign Tax Credit at 97

Troutman Pepper on

As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more

Law Matters

The 3 Most Significant Tax Matters for Multinationals in 2014

Law Matters on

What is the most significant tax consideration facing multinationals in 2014? That’s the question we recently put to leading tax advisors, asking for their quick take on the matter as we launch our new 'Need to Know' series....more

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