United States
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
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
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
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Sponsored by EY Asia-PacificThe indicators point in one direction: an increase in tax controversy, as authorities’ resources are ploughed into increased scrutiny. Luis Coronado of EY explains why, and suggests what tactics businesses should be adopting. -
Sponsored by KPMG USMark 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.
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Sponsored by KPMG USMark 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.
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