In 1998 the IRS and the Treasury Department got the attention of the outbound international tax community by issuing Notice 98-5. The notice sought to challenge certain tax-motivated transactions that generated foreign tax credits (FTCs) by testing their substance under an economic profits test. The transactions described in Notice 98-5 were later included as "listed transactions" subject to the tax shelter disclosure, registration and list maintenance requirements.
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The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four
HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test