On August 12, 2015 the IRS released two final revenue procedures impacting the U.S. transfer pricing regime. Revenue Procedure 2015-40 concerns the protocols and procedures for requesting assistance of the U.S. competent authority (CA) and the other, Revenue Procedure 2015-41, the protocols and procedures for seeking an Advance Pricing Agreement with the IRS.[1] In 2013…
Please contact us to assist in our research Prof. William Byrnes & Haydon Perryman In 2011, HMRC forecast that it would receive “billions” from the Swiss Disclosure Facility. In 2012, HMRC stated that this number would be five billion sterling, and another three billion sterling from the Liechtenstein Disclosure Facility (LDF). This implies that at least a couple hundred thousand United Kingdom tax…
Attacking Profit Shifting by Prof. Jeffery Kadet (Abstract) In recent years the financial press has turned increasing attention to MNCs that shift income to low taxed jurisdictions overseas in order to avoid US taxation. What’s generally missing from these discussions is any serious focus on possible IRS attacks on these companies, most of which are CFCs. There’s little…
FFI GIIN List FATCA Monthly Update The IRS released the fourteenth FATCA GIIN list of foreign financial institutions (FFIs) that have registered with the IRS through its FATCA portal. The IRS provides these FFIs a Global Intermediary Identification Number (GIIN). The FFI may then use its unique 19 digit GIIN to complete the IRS tax…
Dr. Andrew P. Morriss is Dean & Anthony G. Buzbee Dean’s Endowed Chairholder, Texas A&M University School of Law; Drew Estes is a JD/MBA Candidate, Class of 2016, University of Alabama. Excerpted from Kluwer CCH’s Global Tax Weekly Magazine Introduction Tax competition is usually portrayed as a competition over rates. Critics argue that such competition leads inevitably…
The FFI GIIN List Update (Lists from June 1, 2014 through June 1, 2015) On 1 June 2015 the IRS published its thirteenth FATCA GIIN list of “approved FFIs” (a list of the financial firms that have registered on the IRS FATCA portal). Total approved FFIs reached 165,461, and increase of only 2,851 during the…
Dr. Andrew Morriss, Dean of Texas A&M University School of Law The rapidly shifting world of international financial and tax regulation – from the OECD’s BEPS to FATCA – is reshaping the world. Many of these policies are being adopted without regard to whether they produce net benefits (e.g. revenue in excess of the costs…
1. FBAR Filing Requirement The FBAR refers to Form 114, Report of Foreign Bank and Financial Accounts. The FBAR must be filed annually by a U.S. person that has a financial interest in or signature authority over foreign financial accounts if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the…
Three significant filing deadlines fall in June, one today and two more on the last day of the month. (1) The 15 June FATCA Form 8938 filing deadline (with the income tax return) with the IRS for a U.S. person who lives abroad and has specified foreign assets of at least $50,000 on the last…
This month’s Haydon Perryman and William Byrnes FATCA Update post starts with a tip-of-the-hat to my FATCA and CRS research colleague Haydon Perryman who has just moved to UBS Investment Bank where he will be responsible for global regulatory reporting of FATCA and the CRS. Haydon Perryman summed up the decline in GIIN registration during April:…
GIIN Lists Analysis: June 2014 through April 2015 April’s global GIIN registrations, like March, were unimpressive. Financial institution GIIN total registrations ticked up from an unimpressive 2,479 additional ones in March to 3,734 in April, bringing the ultimate GIIN count to 160,010 from the March result of 156,276. The 112 IGA signatories, and IGA agreements…
GIIN Lists Analysis: June 2014 through March 2015 In the words of my English colleague Haydon Perryman, March was a “bit of a damp squib”. Financial institution FATCA registrations have slowed to a trickle with only 2,479 additional ones seeking a GIIN, bringing the ultimate total to 156,276. Of this total, the UK and its…
General Introduction From 1 July 2014, U.S. withholding agents have imposed, with very limited exceptions, the new Internal Revenue Code (IRC) Chapter 4 withholding (a.k.a. FATCA) of 30 percent on ‘withholdable’ payments to foreign financial institutions (FFIs) that do not appear on the IRS’ published GIIN list. However, U.S. Treasury delayed the imposition of the…
