US issues Revenue Procedure – CbC report filing

Revenue Procedure 2017-23 was issued by the Internal Revenue Service on 19 January 2017 and sets out the process for filing Form 8975 Country-by-Country Report. Form 8975 and its accompaniment Schedule A, Tax Jurisdiction and Constituent Entity Information are both...

Country-by-country reporting is here to stay

Globally, there has been a noticeable increase in countries preparing for country-by-country (CBC) reporting pursuant to the OECD’s BEPs Action Plan (‘Plan’). Action 13 of the Plan: Country-by-Country Reporting covers these recommendations: The...

2016 Foreign Housing Limitation Adjustments

The Internal Revenue Service (IRS) recently issued Notice 2016-21, setting the country-by-country limitation on housing expenses deductible under section 911 of the Internal Revenue Code for 2016. The housing expenses deduction enables a qualifying taxpayer to include...

OECD Base Erosion and Profit Shifting project

In addition to the newly negotiated and highly controversial TPP agreement, the rollout of the OECD’s Base Erosion and Profit Shifting (BEPS) project has New Zealand’s political and business leaders in heated discussions this week.   The business...

Worldwide reactions – BEPS recommendations

We are seeing an astounding amount of activity amongst various countries and groups as they consider the recommendations made under the OECD’s Base Erosion and Profit Shifting (BEPS) project. G20 leaders have endorsed the recommendations at the G20 summit in...