November’s edition of our newsletter highlights key topics such as the new position in the social security treatment of equity inventive plans in Belgium, the proposed overhaul of tax residency rules for individuals in Australia and much more.
All of our articles are produced by our global expatriate tax professionals to ... read more
September 2017, the IRS released a Directive (LB&I-04-0917-005) providing Large Business & International (LB&I) Division taxpayers the option of applying a “safe harbor” to determine certain expenses that are included under the Internal Revenue Code Section 41 research credit (Research Credit). The guidance set forth that qualified research expenses (QREs) ... read more
On November 28, 2018, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued proposed regulations (the Proposed Regulations) that provide guidance relating to the determination of the foreign tax credit. The guidance relates to changes made to the applicable law by the 2017 tax reform, also ... read more
On November 26, 2018, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) issued proposed regulations under Section 163(j) (the Proposed Regulations). The Proposed Regulations provide general rules and definitions along with rules for calculating the limitation in consolidated group, partnership, and international contexts.
This issue of TP Review covers important changes around the world in today’s transfer pricing climate.
This month, many of the updates focus on updated guidance and increased implementation of the OECD’s BEPS measures. In the United States, U.S. cost sharing regulations remain under scrutiny ... read more
This newsletter summarizes recent tax developments of international interest across the world. In this issue:
The Netherlands’ 2019 Tax Budget;
Permanent establishment in India from services for processing card payment transactions;
The UK 2018 Budget;
Implementation of ownership disclosure requirements for Brazilian corporate taxpayers; and
Other tax news from around the world.
As 2018 draws to a close, we remind you about the proper inclusion of common fringe benefits in an employee’s and/or two-percent shareholder’s taxable wages, as well as changes made under the 2017 tax reform, referred to herein as the Tax Cuts and Jobs Act (TCJA). Fringe benefits are defined ... read more
On November 18, the IRS released final regulations (TD 9843) modifying Sections 1.263A-1, -2 and -3 of the Income Tax Regulations to address the allocation of certain costs to property produced or acquired for resale by the taxpayer. The regulations clarify the treatment of negative adjustments related to certain costs ... read more
As board responsibilities continue to expand beyond the traditional boundaries of strategic planning and general risk management, director pay levels are increasing. At the same time, scrutiny around compensation practices for boards is intensifying. Developing a deeper understanding of board compensation trends is critical to attract and retain talented board ... read more
On October 23, Massachusetts enacted House Bill 4930 (H. 4930), the state’s supplemental appropriations bill for fiscal 2018. H. 4930 also addresses the treatment of Subpart F income and Global Intangible Low-Taxed Income (GILTI) for corporate excise tax, financial institution excise tax, and personal income tax purposes in response to ... read more