Clicky IRS Expands Virtual Currency Tax Guidance

On October 9, 2019, the United States Internal Revenue Service issued two new pieces of guidance for taxpayers who engage in transactions involving virtual currency. IRS Grants Relief For US Persons Affected By Section 958 Repeal

On October 1, 2019, the United States Treasury Department and the Internal Revenue Service announced a relief for certain US persons that own stock in certain foreign corporations. Sanders Unveils US Wealth Tax

United States Senator Bernie Sanders (D-VT), a leading contender for the Democratic presidential nomination, has proposed a new tax, as well as a series of enforcement measures, targeting America's wealthiest individuals. More US States To Tax Remote Sales From October

Many US states will begin to impose sales and use tax obligations on remote sellers and marketplace facilitators from October 1, 2019, largely in response to the United States Supreme Court's landmark decision in the Wayfair case. US-Switzerland Double Tax Protocol Now In Force

The Swiss Government on September 20, 2019, announced that it has exchanged instruments of ratification with the United States to bring into force a Protocol to their double tax agreement. Apple's Irish Tax Ruling Appeal Gets Underway

The Irish Government is arguing that favorable tax treatment was not granted to Apple under two rulings deemed by the EU to have constituted illegal state aid to the company. IRS Offers Settlement Scheme To Micro-Captives

On September 16, 2019, the United States Internal Revenue Service announced the mailing of a time-limited settlement offer for certain taxpayers under audit who participated in abusive micro-captive insurance transactions. Poland Said To Have Ditched Plans For Digital Tax

According to a recent comment by United States Vice President Mike Pence, the Polish Government has decided not to proceed with a national digital services tax. US And France Nearing Digital Tax Compromise

The Governments of France and the United States are reportedly close to settling a dispute surrounding France's digital services tax. IRS To Provide GILTI Penalty Relief To Pass-Through Entities

On August 22, 2019, a notice was published which announces the intention of the United States Treasury Department and the Internal Revenue Service to issue new regulations providing relief to domestic partnerships and S corporations attempting to comply with final global intangible low-taxed income regulations with respect to shareholdings in controlled foreign corporations. President Trump Considering New Tax Cuts

United States President Donald Trump said on August 20, 2019, that the administration is considering additional tax cuts to help maintain economic growth. USTR Stages Hearing On French Digital Tax Response

On August 19, 2019, the Office of the United States Trade Representative held an off-camera public hearing on France's recently introduced digital services tax, attended by three major technology firms. US Appeals Court Backs Amazon In Transfer Pricing Case

On August 16, 2019, the United States Court of Appeals for the Ninth Circuit issued a decision in favor of Amazon, in a case involving the regulatory definition of intangible assets and the method of their valuation in a cost-sharing arrangement. OECD Releases Action 14 Peer Reviews For Six States

The OECD on August 13, 2019, released follow-up reports for Belgium, Canada, the Netherlands, Switzerland, the United Kingdom, and the United States on their efforts to implement BEPS recommendations on dispute resolution. LLB-Switzerland Signs US Non-Prosecution Agreement

On August 5, 2019, the US Department of Justice announced that Swiss bank LLB Verwaltung (Switzerland) AG has agreed to pay a penalty of USD10.6m to resolve a case in which it was accused of helping US clients to conceal income. IRS Responds To Altera Ruling On Cost Sharing Arrangements

On July 31, 2019, the United States Internal Revenue Service issued a memorandum for all Large Business and International Division employees informing them of the withdrawal of a directive regarding cost sharing arrangements in the light of the recent Court of Appeals ruling in the Altera case. US Senators Urge 'Fairness' Change To Capital Gains Tax Calculations

A group of 21 Republican members of the US Senate have signed a letter to the Treasury Secretary urging him to amend how capital gains tax liability is calculated. Bulgaria Approves CbC Exchange Agreements With US

Bulgaria's Council of Ministers earlier this month approved two agreements with the United States allowing for the automatic exchange of country-by-country transfer pricing reports. IRS Clarifies FTC Rules For French Social Taxes

On July 19, 2019, the United States Internal Revenue Service updated its webpage on foreign tax credits to clarify that it will not challenge foreign tax credit claims involving certain French taxes. IRS's New Enforcement Initiatives Are Aimed At Individuals

On July 19, 2019, the United States Internal Revenue Service Large Business and International Division announced six additional compliance campaigns. G7 Backs OECD In Push For Global Digital Tax Response

G7 finance ministers have said that there is an urgent need to address the tax challenges posed by the digitalization of the economy. US Senate Approves Changes To Four Double Tax Pacts

The United States Senate has approved protocols to four existing bilateral double tax avoidance treaties that have been pending in the chamber for as much as a decade. IRS Provides Additional Transition Tax Guidance

On July 16, 2019, the United States Internal Revenue Service announced the publication of additional information to help taxpayers meet their filing and payment requirements in respect of the Section 965 transition tax on untaxed foreign earnings. US Senate To Vote On Tax Treaty Protocols

The United States Senate could soon approve ratification of four long-pending double tax avoidance treaty protocols. Seychelles Signs US FATCA Agreement

On July 3, 2019, the Seychelles Government announced that it has signed an intergovernmental agreement with the United States to implement the requirements of the US Foreign Account Tax Compliance Act. US Senate Finance Committee Approves Four Treaties

On June 25, 2019, the United States Senate Foreign Relations Committee approved amendments to four double tax avoidance agreements which have been pending in the Senate for several years. US Senate Finance Committee Seeks Response To French Digital Tax

The leaders of the United States Committee on Finance have written Treasury Secretary Steven Mnuchin urging him to use "all tools available" to counter France's proposed digital services tax, which they argue unfairly discriminates against US companies. IRS Opens US Compliance Assurance Program To Applicants

On June 14, 2019, the US Internal Revenue Service announced that it is looking for new applicants for the Compliance Assurance Process (CAP), a cooperative compliance program aimed at publicly traded corporate taxpayers. US Congress Passes IRS Reform Bill

On June 13, 2019, the US Senate approved the Taxpayer First Act, which is intended to overhaul the Internal Revenue Service and strengthen taxpayer rights. US House Passes IRS Reform Bill

On June 10, 2019, the United States House of Representatives approved legislation which would reform the rules governing the Internal Revenue Service.