On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more
DAC6 summary -
Council Directive 2018/822 – known as DAC6 – is the sixth amendment to the EU Directive on Administrative Cooperation 2011/16/EU. DAC6 is aimed at providing the tax authorities with a “warning system” in...more
5/29/2020
/ Coronavirus/COVID-19 ,
Cross-Border Transactions ,
DAC6 ,
Delays ,
EU ,
European Commission ,
France ,
Germany ,
HMRC ,
Implementation Day ,
Member State ,
Reporting Requirements ,
Tax Authority ,
Tax Planning ,
UK
On December 2, 2019, the Office of the US Trade Representative (USTR) announced its determination that France's Digital Services Tax (DST) is "unreasonable or discriminatory and burdens or restricts U.S. commerce" and is...more
12/11/2019
/ BEPS ,
Digital Services Tax ,
France ,
OECD ,
Proposed Rules ,
Section 301 ,
Tariffs ,
Trade Restrictions ,
Trump Administration ,
USTR ,
WTO
On July 10, 2019, the Office of the United States Trade Representative (USTR) initiated an investigation under Section 301 of the Trade Act of 1974 to determine whether a Digital Services Tax (DST) recently approved by the...more
7/16/2019
/ Digital Service Providers ,
Digital Services Tax ,
Discrimination ,
France ,
Imports ,
International Tax Issues ,
Public Comment ,
Request For Information ,
Retaliatory Tariffs ,
Retroactive Taxes ,
Section 301 ,
USTR ,
WTO
The Taxpayer First Act of 2019 ("TFA")1 has passed both chambers of Congress and will likely soon be signed into law by the President. The bill has a wide range of provisions affecting and modernizing the Internal Revenue...more
6/21/2019
/ Administrative Appeals ,
Administrative Procedure ,
Administrative Procedure Act ,
Due Process ,
Impartiality ,
IRS ,
IRS Independent Office of Appeals ,
Pending Legislation ,
Right To Appeal ,
Tax Appeals ,
Tax Reform ,
Taxpayer First Act of 2019 (TFA) ,
Trump Administration