International Tax News

IRS to Modify Regs on Some “Triangular” Reorganizations

The IRS said it plans to modify the regs relating to certain triangular reorganizations involving foreign corporations. Specifically, in Notice 2016-73, the tax agency announced it will alter the rules affecting the treatment of property used to acquire parent stock or securities in triangular reorganizations involving one or more foreign corporations, as well as describe…

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Draft Instructions Available for Form 8975

On February 23, 2017, the U.S. IRS published draft Instructions for Form 8975 and Schedule A (Form 8975), Country-by-Country Report (CbC Report). Note that these are in draft form and may change prior to the IRS issuing a final version. This document will be updated to address any changes. A U.S. person must file a…

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“Google Tax” Goes into Effect in Russia

Moscow enacted a law ordering certain foreign companies engaged in online sales of electronic content in Russia to pay the value-added tax (VAT). Equal Footing The law, informally known as the “Google Tax,” stipulates the introduction of an 18% VAT for foreign companies providing services to Russians in electronic form. Foreign companies will need to…

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IRS Regs Kill Foreign Goodwill Exception

Final IRS Regs Kill Foreign Goodwill Exception, Curb Active Trade Exception The IRS issued final regs that affect U.S. taxpayers who transfer property to foreign corporations in nonrecognition transactions. The regs are aimed at preventing taxpayers from avoiding recognition of gains or income attributable to high-value intangible property by claiming that a large share of…

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SSA publishes January 2017 Update

The Social Security Administration (SSA) published its January 2017 update and covers the following topics:  Finland Implements Reform to Earnings-Related Pension Program Poland Approves Law Lowering Retirement Ages Japan’s Legislature Approves Public Pension Reform Provisions Uruguay and the United States Sign Totalization Agreement Of particular interest is the last topic concerning the U.S. / Uruguay…

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