With the US recently proposing changes to the regulations under section 892 of the US Internal Revenue Code concerning investment through controlled entities by foreign governments including typical sovereign wealth funds, Peter Blessing and Ansgar Simon of Shearman & Sterling in New York provide an update on the US position and briefly compare the overall approach taken in the US with that taken in the UK, France and Germany.
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The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
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’
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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