KPMG US

Mark Martin and Thomas Bettge of KPMG in the US review recent Internal Revenue Service enforcement efforts regarding foreign corporations’ US income tax returns, and discuss the waiver process for taxpayers with untimely returns.

Mark Martin and Thomas Bettge of KPMG in the US discuss the inclusion of updates to the US Internal Revenue Service’s (IRS) mutual agreement procedure (MAP) and advance pricing agreement (APA) revenue procedures in its priority guidance plan, and consider how successor guidance could further improve the MAP and APA programmes.

Mark Martin and Thomas Bettge of KPMG in the US discuss the recent OECD public consultation documents on tax certainty for Amount A of pillar one and related issues, and review key areas that remain undecided.