The Netherlands and other EU member states could be forced into changing their tax legislation if the European Court of Justice (ECJ) confirms an Advocate General's view in cases relating to whether Dutch companies can freely establish fiscal unities with members of the same group.
Alcoa’s operations in Europe, Middle East and Africa run from Norway in the north of the region to South Africa in the south. It is a wide area of responsibility for the EMEA tax department of the global engineering and manufacturing company, which makes it crucial that when it uses external advisers, it finds the right ones to help it contribute to the company’s objectives.
The US Treasury and Internal Revenue Service have responded to industry concerns in the final and temporary regulations for the Foreign Account and Tax Compliance Act (FATCA). However, the effective date of July 1 2014 was not changed.
Practitioners are hoping US Internal Revenue Service (IRS) agents will get more discretion when a directive on the Information Document Request (IDR) enforcement process is reissued soon.
Canada has overcome concerns about America’s Foreign Account Tax Compliance Act (FATCA) and signed a bilateral intergovernmental agreement (IGA) with the US to implement it.