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US Archive

  • June 2018

    Andersen Global bolsters Brazilian tax practice

    June 19, 2018

    Andersen Global continues its growth in Latin America with the addition of Lotti e Araujo, a Brazilian corporate law firm with particular expertise in tax litigation, as well as the civil and labour sectors.

  • How multinationals beat a US city council

    June 18, 2018

    Amazon and Starbucks won their battle with Seattle City Council to prevent a new tax on big employers coming into effect. But what does this say about the relationship between taxpayers and local government?

  • Alvarez & Marsal Taxand adds two senior directors in Denver and New York

    June 15, 2018

    Jon de Jong and Louis Mancini have joined Alvarez & Marsal Taxand, an affiliate of the global firm Alvarez & Marsal, as senior directors.

  • Wall Street waits for US tax reform 2.0

    June 14, 2018

    Wall Street banks are delaying tax restructuring while they wait for the US Congress to present a new tax bill before the 2018 mid-term elections.

  • US Supreme Court decision in Wayfair sales tax case imminent

    June 13, 2018

    The US Supreme Court’s decision in the seismic South Dakota v Wayfair case, which concerns state sales tax, should be released before the end of June. It could leave companies around the world facing retroactive exposure in the billions of dollars.

  • How reform in the US affects Microsoft’s tax structure

    June 11, 2018

    Ireland, Puerto Rico, Singapore and other traditional tax structuring jurisdictions could be set to lose out if Microsoft’s response to Donald Trump’s US tax reform is representative of that of other multinationals.

  • Will Cejudo joins Dechert in Washington DC

    June 11, 2018

    Dechert has added Will Cejudo as a partner in the firm’s international and domestic tax practice group. He will focus on tax matters relating to structured finance transactions.

  • Euromoney LMG Americas Women in Business Law Awards 2018: winners announced

    June 08, 2018

    The best women lawyers in the Americas gathered at the JW Marriott Essex House hotel in New York last night to celebrate the achievements of women across firms, practice areas and jurisdictions.

  • Matheson makes Barry McGettrick partner in its Dublin tax practice

    June 07, 2018

    Irish law firm Matheson has promoted Barry McGettrick to partner in its Dublin tax practice.

  • How Amazon and eBay will comply with Australia’s GST changes

    June 07, 2018

    International Tax Review analyses the different ways Amazon and eBay are adapting to be compliant with Australian GST laws once low-value goods are no longer exempt from July 1.

  • Carbon taxation revenue rose by 50% in 2017 – or did it?

    June 05, 2018

    Global revenue from carbon pricing rose by 50% in 2017 compared to 2016, says a new report from the World Bank. While companies can expect green taxes to keep rising, this statistic doesn’t quite tell the whole story.

  • James Jackson lands DIGI role at TIGTA’s Office of Investigations

    June 01, 2018

    James Jackson has become deputy inspector general for investigations (DIGI) at the US Treasury Inspector General for Tax Administration (TIGTA) following his service role as ‘acting’ DIGI since January 1 2018.

  • Is GDPR putting companies off the UK’s anti-VAT fraud scheme?

    June 01, 2018

    While Amazon, eBay and Fruugo have signed up to HMRC’s new disclosure scheme for VAT fraud, major online marketplaces like Etsy and Alibaba have not. Advisers suspect GDPR may be partly to blame.

  • May 2018

    KPMG adds to US tax practice

    May 31, 2018

    KPMG has made seven new hires in its US tax practice.

  • David Wheat joins Kirkland & Ellis’s tax team in Houston

    May 30, 2018

    David Wheat has joined Kirkland & Ellis’s tax practice group as a partner in the firm’s Houston office.

  • Why McDonald’s has restructured its tax affairs

    May 30, 2018

    Facing fresh claims of tax avoidance, McDonald’s has defended its tax structure, telling International Tax Review why it moved its intellectual property (IP) from Luxembourg to the UK.

  • Bracewell expands New York team

    May 29, 2018

    Bracewell has added three new partners and an associate to its litigation team in New York.

  • Global interest limitation rule: A matter of time?

    May 29, 2018

    The US, EU member states and other countries have proposed and/or adopted a limitation rule for the deduction of interest by a corporate taxpayer. Will the OECD try to provide worldwide guidance for interest limitation? Is there an expectation for this guidance in the next several years?

  • The irresistible rise of Andersen Tax

    May 29, 2018

    Josh White speaks to Andersen Global Chairman and CEO Mark Vorsatz about the firm’s ambitions and the long shadow cast by its predecessor.

  • US Inbound: Sale of partnership interest

    May 29, 2018

  • IRS issues APA statistics for 2017

    May 29, 2018

    Mark Martin and Cameron Taheri of KPMG take a closer look at the IRS's APA statistics for 2017.

  • Cyrus Daftary joins KPMG in the US

    May 24, 2018

    Cyrus Daftary has joined KPMG’s financial services global banking practice as principal of the group’s information reporting and withholding tax practice.

  • Big data will make or break use of the cloud for tax reporting

    May 24, 2018

    Implementing digital tax compliance tools are inevitable for corporations as real-time tax reporting gains momentum. But using cloud reporting may expose some tax teams to data risks.

  • MNEs get easy ride under US repatriation and GILTI regimes as US expats pick up the bill

    May 22, 2018

    Although the 2017 US Tax Cuts and Job Act (TCJA) aimed to cut taxes for all Americans, individual US shareholders of controlled foreign corporations (CFCs) living outside the US (expats) are being discriminated against under the repatriation and GILTI tax regimes. Monte Silver of Silver & Co in Israel explains why the likes of Google and Apple are getting a good deal.

  • New slate of executive officers elected for IFA USA

    May 17, 2018

    A new slate of executive officers were elected for the US branch of the International Fiscal Association (IFA USA) at its February 23 annual meeting in Houston, the IFA announced on May 7.

  • Vertex promotes Bernadette Pinamont

    May 08, 2018

    Vertex has promoted Bernadette Pinamont to vice president of tax research.

  • Coca-Cola optimistic ahead of IRS dispute ruling

    May 04, 2018

    As the trial nears its end, Coca-Cola is confident of its chances of winning the high-stakes case against the IRS, according to the company’s 10k filing. The IRS is demanding $3.3 billion in back taxes, plus interest.

  • Alvarez & Marsal hires new managing directors in the US

    May 03, 2018

    Alvarez & Marsal Taxand has hired Jay Helverson and Rick Gardner, and several professionals from their team, from WTS US.

  • April 2018

    The Brockman brief: Legal entity simplification: the time is now

    April 30, 2018

    As the US has tried to ‘level the playing field’ with the Tax Cuts and Jobs Act enacted in December 2017, coupled with additional complexities and subjective interpretations around the world, it is time to reflect upon legal entity simplification.

  • Goldman Sachs invests in Argentina after Macri’s tax reform

    April 30, 2018

  • Q&A: Ex-Microsoft tax adviser Mike Bernard on data and the digital economy

    April 30, 2018

    Mike Bernard, former Microsoft tax counsel, talks to ITR about his experience at Microsoft, how the tax department functioned, and how he will help MNEs use data to be audit-ready in his new role at Vertex.

  • Plenty on planners’ plates: Tax Planning Survey 2018

    April 30, 2018

    The US Tax Cuts and Jobs Act and other countries’ responses to it, the BEPS project, various exchange of information agreements, incoming tax treaty changes and national elections are just a few of the obstacles ensuring that tax professionals have plenty of planning on their plates in 2018.

  • Digital issues and EU VAT reform take centre stage at ITR’s Indirect Tax Forum

    April 30, 2018

    The OECD’s David O’Sullivan opened ITR’s Indirect Tax Forum by talking about the role which web companies can play in collecting VAT and GST. Subscribers and delegates can download his presentation – and those of other speakers, including the EU’s Maria Teresea Fábregas – here.

  • US Inbound: Sale of partnership interest

    April 30, 2018

    The Tax Cuts and Jobs Act (2017 Act) overturned Grecian Magnesite v Commissioner, which held that the sale by a foreign person of its interest in a partnership engaged in a US trade or business was not subject to US tax.

  • US tax reform: the pitfalls of Section 965 on foreign earnings

    April 30, 2018

    The Internal Revenue Service (IRS) has left many questions unanswered about the impact of Section 965 on foreign earnings with Notice 2018-26.

  • Americas Tax Awards 2018: Enter now

    April 27, 2018

    The submissions period for this year’s Americas Tax Awards is open. Private-practice firms, in-house companies and individual tax professionals can win.

  • Raising capital from Mexican pension funds

    April 13, 2018

    In recent years, Mexican government agencies, including the Mexican Banking and Securities Commission (CNBV) and the National Retirement Savings System Commission (CONSAR) have implemented regulatory changes with the intent of allowing investors in general and specialised retirement fund investment companies in particular, to better diversify their holdings while at the same time providing the private sector with additional fundraising alternatives.

  • Proskauer hires Jeremy Naylor in New York

    April 10, 2018

    Jeremy Naylor has joined the New York tax practice of Proskauer, an international firm specialising in investments, as a partner.

  • US Treasury Department’s Dana Trier moves back to Davis Polk

    April 09, 2018

    Davis Polk & Wardwell has announced that Dana Trier, who resigned unexpectedly from the US Treasury Department in February 2018, has come back to the firm.

  • Loconte&Partners opens New York office

    April 08, 2018

    Italian tax law firm Loconte&Partners has opened an office in New York.

  • Goal Group opens Manhattan office

    April 06, 2018

    London-headquartered firm Goal Group opened a new office in Manhattan’s financial district on March 12.

  • The case against the robot tax

    April 05, 2018

    Taxing corporate income generated through the use of robots may be a popular idea, but the difficulty of drawing a link between the use of artificial intelligence (AI) and corporate income could create a new avenue for tax avoidance and hold back innovation.

  • Blockchain – $62 billion VAT fraud buster or just another tech bubble?

    April 05, 2018

    Should we ignore the bitcoin speculative bubble and hacking scare stories as the fireflies before the technological storm? Could blockchain solve the EU’s €50 billion ($62 billion) VAT fraud menace, and revolutionise tax reporting?

  • March 2018

    US consultancy firm alliantgroup acquires ForrestBrown

    March 29, 2018

    UK R&D tax credit consultancy firm ForrestBrown has been acquired by US consultancy firm alliantgroup, a leading provider of federal and state tax incentives in the United States.

  • KPMG US appoints three managing directors in tax practice

    March 26, 2018

    Thomas Chamberlin, Gibi Lappin, and Philip Petrillo have joined KPMG.

  • Former Microsoft tax counsel Mike Bernard joins Vertex

    March 23, 2018

    Mike Bernard, former Microsoft tax counsel, has joined Vertex as chief tax officer, replacing Peggi Rockefeller, who is retiring.

  • ITR Women in Tax Forum: Celebrating excellence

    March 21, 2018

    International Tax Review hosted its first Women in Tax Forum in New York on March 1. The event kick-started a month of celebrating the brilliant female minds in the sector, their take on some of the hottest tax matters, and insight into their leadership skills and how to be the best.

  • Inside the Revenue Service: What does the IRS do with your data?

    March 21, 2018

    The US Internal Revenue Service (IRS) is, in many ways, typical of tax authorities around the world – it’s not as well-resourced as it once was. It is being asked to do more with less, and it is turning to data analytics to help it better identify where it should focus its attention.

  • IRS Special: Digging for data with Doug O’Donnell

    March 21, 2018

    Doug O’Donnell, head of the large business and international (LB&I) department in the IRS, speaks to Joe Stanley-Smith about how he runs his large business and international department in the rapidly changing arenas of US and international tax.

  • IRS Special: Running the risk

    March 21, 2018

    Joe Stanley-Smith sits down with Tom Brandt, chief risk officer at the IRS, to discuss managing budget cuts, tax reform and the growing threat of cybersecurity.

  • Embracing tax technology: The full perspective

    March 21, 2018

    Geoff Peck, executive officer and chief taxologist at PawPaw Taxology, dives deeper into how tax leaders can approach tax technology with better clarity and assurance than they do today.

  • Nominate the best tax controversy, indirect and female tax advisers for ITR's leaders guides

    March 19, 2018

    ITR's research team has begun work on the Tax Controversy Leaders guide, Indirect Tax Leaders guide and Women in Tax Leaders guide. This is your chance to nominate the individuals who offer the best tax advice.

  • Could robots reverse the race to the bottom?

    March 16, 2018

    The rise of robotics promises to turn the world of work upside down and corporate tax may have to be raised to make up for the shortfall. This could force the ‘race to the bottom’ into reverse.

  • Mayer Brown hires two MoFo partners

    March 16, 2018

    Mayer Brown has hired two partners, Thomas Humphreys and Remmelt Reigersman, to work in its offices in New York and California, respectively.

  • New anti-avoidance and information sharing measures in Canadian budget

    March 02, 2018

    Canada’s new budget bears little reaction to the US tax reform, but multinational companies should brace for some newly announced anti-avoidance rules and impending international information exchange.

  • February 2018

    Berwin Leighton Paisner and Bryan Cave to merge in April

    February 27, 2018

    US firm Bryan Cave and UK law firm Berwin Leighton Paisner are to merge after the tie up was approved in a vote by partners of both firms on February 26 2018.

  • US tax reform: The tax competition risks to the Netherlands and EU

    February 27, 2018

  • No room for doubt: the ‘race to the bottom’ is on

    February 27, 2018

    Judging by the speeches at the World Economic Forum in Davos, political and business leaders are concerned by the changing dynamics of international tax competition and there can be no doubt that the ‘race to the bottom’ is on.

  • Tax talent: The world's best transactional firms 2018

    February 27, 2018

    Despite global M&A volume exceeding $3 trillion for the fourth consecutive year, there can be no doubt that uncertainty has affected the transactional market during the past year, and will continue to do so in 2018, but this isn’t to say that all of its effects will be negative.

  • Could lower tax demands be the answer to cutting disputes?

    February 27, 2018

    Litigation between taxpayers and authorities is growing worldwide, but a successful outcome is never easy for any party involved in a conflict. Anjana Haines investigates why tax disputes are rising and how to potentially ease the burden.

  • Bitcoin and other cryptocurrencies in tax

    February 27, 2018

    A significant amount of developments have taken place in the past few years, writes Rose Boevé of EY Dutch Caribbean. This includes a surge in cryptocurrencies and in the accompanying regulatory playing field.

  • US tax reform: GILTI uncertainties

    February 27, 2018

    For months, Congress promoted the tax reform effort as being focused on simplifying the outdated and complex 1986 Tax Code. Tax reform, culminating in H.R. 1, did no such thing, at least where it applies to multinational US corporations. Nowhere is this more apparent than in section 951A, the tax on global intangible low-taxed income, or ‘GILTI’. Erik Christenson, partner at Baker McKenzie, and Monte Silver, senior counsel at Eitan, Mehulal & Sadot explain.

  • US Outbound: BEAT to hit inbound taxpayers hard

    February 27, 2018

  • US Outbound: New LB&I directives both change and clarify IRS transfer pricing procedures

    February 27, 2018

  • Stroock & Stroock & Lavan hires special counsel

    February 26, 2018

    Stroock & Stroock & Lavan has appointed Sharon Soloff as special counsel to the firm’s New York tax practice.

  • US Treasury takes aim at 385 regulations

    February 19, 2018

    As part of its effort to cut red tape, the US Treasury Department has singled out the section 385 regulations to be dropped alongside almost 300 tax regulations deemed to be out of date. This is after President Donald Trump called for the Treasury to find ways to reduce the regulatory burden on taxpayers.

  • Kevin Glenn joins King & Spalding

    February 19, 2018

    King & Spalding has appointed Kevin Glenn as a corporate tax partner within the corporate, finance and investments group in the firm’s New York office.

  • Will mandatory disclosures end CRS avoidance?

    February 16, 2018

    The OECD is preparing mandatory disclosure rules (MDRs) to deter some advisers and service providers from actively marketing schemes designed to circumvent the common reporting standard (CRS) reporting requirements. But tax advisers and organisations have raised concerns about the plans.

  • Latham & Watkins hires Jean Pawlow

    February 14, 2018

    Latham & Watkins has appointed Jean Pawlow as partner of the firm’s tax controversy practice, covering Washington DC and Silicon Valley.

  • Watch again: ITR webinar examines 2018 India budget in detail

    February 06, 2018

    On the day of the India budget, International Tax Review and representatives from Dhruva Advisors, Taxsutra and JSW Steel examined the tax implications for multinational companies.

  • January 2018

    India budget 2018: Changes expected for GST, LLPs and start-ups

    January 31, 2018

    Taxpayers can expect numerous changes in India’s 2018 budget, with corporate tax, minimum alternate tax (MAT), goods and services tax (GST), dividend distribution tax (DDT) all likely to be affected.

  • Former KPMG partners charged in US fraud case

    January 31, 2018

    Six accountants including three former KPMG partners are facing charges of fraud in the US over allegations of involvement in a scheme warning of upcoming inspections from the Public Company Accounting Oversight Board (PCAOB). This case raises difficult questions about the regulatory environment in the US.

  • The Brockman brief: Tax subjectivity and complexity: road to nowhere

    January 30, 2018

    The US tax reform act, among other countries’ proposals and legislative pronouncements, has widened the breadth of subjectivity while adding new multiple systems for federal, state and international compliance, seemingly leading to a road to nowhere for tax simplification and transparency.

  • US tax reform: The changes and the next steps

    January 30, 2018

    With the US tax reform bill on the verge of being signed, International Tax Review outlines the key takeaways for multinational companies and looks at what will need to be done in the new year.

  • China gets competitive with foreign investor tax incentive in wake of US tax reform

    January 30, 2018

    A tax war could begin between the world’s two biggest economies after China said it will allow foreign investors to claim a refund for direct investment made in 2018. Can taxpayers expect further perks in 2018 in reaction to the US tax reform?

  • 2018: The busiest tax year yet

    January 30, 2018

    The work of corporate tax departments over the next 12 months will be dominated by large international changes such as the BEPS project, US tax reform and shifting attitudes toward taxation of the digital economy. Joe Stanley-Smith explores what companies can do to stay ahead of the curve.

  • Towards taxation of robots or their use?

    January 30, 2018

    The development of artificial intelligence (AI) and, in particular, of robots is an issue of global significance. Xavier Oberson, professor at the University of Geneva and a specialist in this area examines the societal change towards the use of robots and how to tax them.

  • Webinar: A first glance at India’s 2018 budget

    January 29, 2018

    International Tax Review is pleased to announce that it will be hosting a live webinar on February 1 to analyse the implications of the tax proposals in India’s 2018 budget. Here, we look at what tax proposals may be announced.

  • Upcoming oil and gas bidding rounds in Mexico: relevant tax considerations for investors

    January 29, 2018

    The 2018 Mexican elections, Trump's sweeping tax reform and recent sector specific tax developments are some of the oil and gas industry’s main concerns as we approach the announcement of winning bidders for upcoming rounds 2.4 (deep waters) and 3.1 (shallow waters). Amid this environment, we discuss our views into what investors should expect in relation to tax developments.

  • Orrick appoints tax partner

    January 28, 2018

    Orrick has promoted Wolfram Pohl to partner at its tax team in San Francisco. Pohl is one of 19 new partners appointed by the firm.

  • Google is happy to pay more tax, says CEO

    January 25, 2018

    In his speech to the World Economic Forum in Davos, Google CEO Sundar Prichai declared that the tech company is “happy to pay more” in taxes and called for the international tax system to be reformed. His comments come during heightening international debate on how to fairly tax the high-tech economy.

  • US tax reform focus: Ireland’s good fortunes

    January 24, 2018

    As Ireland has long been a prime destination for US investment, the US tax reform has raised questions for the Irish tax model and how it will stand its own following the Tax Cuts and Jobs Act was passed. Companies like Facebook and Apple have recently overhauled their tax arrangements, and Ireland faces several other external threats to its tax system.

  • Apple expands US operations after Tax Cuts and Jobs Act

    January 22, 2018

    In a move which seemingly vindicates the tax cuts in the US tax reform bill, Apple has announced it will be expanding its US operations. But this may just be the tip of the iceberg, as some of the biggest companies in the world are looking to follow Apple’s example.

  • Baker McKenzie promotes nine in tax practice across North America

    January 22, 2018

    Baker McKenzie has elected five new partners, one counsel and three directors in its tax practices in Chicago, New York and Mexico City as part of its promotions in North America.

  • The reporting and taxability of cryptocurrencies

    January 19, 2018

    Whoever thought that today’s investor would be trading something called Bitcoin, a valuable item that neither resembles a metal coin or paper certificate? It’s amazing to think that a single line of code can be valued at $16,000 or more. How are these virtual currencies even regulated? For now, it seems there are more questions than answers regarding cryptocurrencies.

  • Jessica Tien becomes principal economist at DLA Piper

    January 19, 2018

    DLA Piper has appointed Jessica Tien as a principal economist in Silicon Valley to focus on transfer pricing matters.

  • Withers promotes four tax partners

    January 16, 2018

    Withers International has promoted four tax partners in New York and London as part of a series of legal appointments.

  • How Facebook could threaten Ireland’s tax revenue boom

    January 11, 2018

    The Irish government has declared its first budget surplus in a decade and many observers have attributed this to corporate tax receipts, but Facebook’s decision to change its business model poses risks to government coffers if other MNEs follow suit.

  • Hogan Lovells promotes two to counsel

    January 03, 2018

    Hogan Lovells has announced two promotions in its tax departments in London and New York.

  • Will US tax reform spark a new ‘race to the bottom’?

    January 02, 2018

    The US’s long-awaited tax reform has brought the country’s corporate tax rate down to 21% - below 2017’s OECD average rate of around 25%. Will this spark a new wave of tax competition?

International Tax Review Profile

Annika Lindstrom and Maria Andersson of @KPMG discuss how BEPS Actions 8 to 10 are being interpreted in relation to… https://t.co/e05Pfob2fQ

Jun 19 2018 12:18 ·  reply ·  retweet ·  favourite
International Tax Review Profile

International Tax Review is hiring! https://t.co/v6G8gcGd9A

Jun 19 2018 11:33 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @JudithFreedman: At Buckingham Palace to collect my CBE for tax research and found I was in programme as Lady Freedman (because husband…

Jun 18 2018 09:15 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related… https://t.co/fJXpvx61b8

Jun 15 2018 06:59 ·  reply ·  retweet ·  favourite
International Tax Review Profile

A US Supreme Court decision in #Wayfair, affecting the applicability of sales tax to e-commerce, could come as soon… https://t.co/Z6ZwcTwjIU

Jun 13 2018 09:57 ·  reply ·  retweet ·  favourite
International Correspondents