Practitioners have said the decision to move responsibility for the US advance pricing agreement programme (APA) and mutual agreement procedure (MAP) from the Office of Chief Counsel to the IRS commissioner has as much to do with the faith in the ability of Mike Danilack, deputy commissioner (international) of the Large and Mid-Size Business Division (LB&I), as it has to do with efficiency.
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The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict
The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles