CSA netting for BEAT should still work despite Treasury’s reticence Mark Martin and Thomas Bettge of KPMG US explain what the final BEAT regulations had in store for the much-discussed netting provisions. By Mark Martin & Thomas Bettge January 29 2020
OECD GloBE consultation focuses on details but overall design remains hazy Mark Martin and Thomas Bettge of KPMG in the US examine the OECD’s public consultation document under Pillar Two of its work on the tax challenges of the digitalisation of... By Mark Martin & Thomas Bettge January 06 2020
US Outbound: OECD’s unified proposal on pillar one poses challenges for dispute resolution Mark Martin and Thomas Bettge of KPMG in the US explore how the OECD’s new proposal on digital era taxation will affect existing dispute resolution tools. By Mark Martin & Thomas Bettge December 17 2019
OECD releases updated proposal on digital era taxation Mark Martin and Thomas Bettge of KPMG in the US examine the OECD’s new proposals for a ‘unified approach’ to digital economy taxation, which are open to public comment until... By Mark Martin & Thomas Bettge October 24 2019
US outbound: OECD statistics show continued effectiveness of MAP cases globally and in US The OECD recently published statistics on mutual agreement procedure (MAP) cases for 2018. By Mark Martin & Thomas Bettge October 15 2019
OECD statistics show continued effectiveness of MAP cases globally and in US Mark Martin and Thomas Bettge of KPMG in the US examine recent OECD statistics on mutual agreement procedure cases, showing that such cases continue to be resolved effectively both in... By Mark Martin & Thomas Bettge October 03 2019
US outbound: IRS CAP programme reopens with attention to transfer pricing Mark Horowitz, Thomas Bettge, Mark Martin, and Theresa Kolish of KPMG assess the IRS’s reopening of the CAP programme, noting that the updated programme seeks to address transfer pricing issues. By Mark Martin & Thomas Bettge August 29 2019
US Outbound: New updates to CAP focus on transfer pricing issue resolution On August 27 2018, the Internal Revenue Service (IRS) announced changes to the compliance assurance process (CAP) for future years. By Mark Martin & Thomas Bettge October 15 2018
IRS issues APA statistics for 2017 Mark Martin and Cameron Taheri of KPMG take a closer look at the IRS's APA statistics for 2017. By Mark Martin & Cameron Taheri May 29 2018
US Outbound: New LB&I directives both change and clarify IRS transfer pricing proce... By Mark Martin & Cameron Taheri February 27 2018
