Donald Moorehead, partner at Squire Patton Boggs in Washington, DC, assesses the prospects for action towards US tax reform in 2015, explaining that it's no surprise many are looking back at 1986 - the last time reform was achieved - for keys to unlock the process, but significant challenges remain.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems