On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House...more
At the request of concerned countries, the Organisation for Economic Co-operation and Development (OECD) Secretariat has weighed in on tax considerations that are important both to businesses and to their employees as they...more
After numerous years in treaty limbo, the US Senate recently provided its advice and consent for ratification of four protocols with Luxembourg, Switzerland, Japan and Spain, setting the stage for the protocols to enter into...more
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
4/29/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
FATCA ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OECD ,
Offshore Banks ,
OVDP ,
Related Parties ,
Transfer Pricing