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Tax Planning in a World of Increased Transparency

Multinational Enterprises (MNEs) are facing an evolving international tax landscape with long-term implications for tax compliance, planning and controversy. Understanding these changes requires continual effort. Tax Executives Institute recently invited us to explore Country-by-Country (CbC) reporting issues at the 2017 Global Tax Symposium in Houston, Texas. We had a lively discussion and know this will be a hot topic as jurisdictions begin reviewing the CbC reports. As background, the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) project has been a key driver of international tax reform.  BEPS “Action 13” outlined a CbC reporting standard that has been adopted in more than 55 jurisdictions. The CbC report is an annual filing obligation identifying, among other things, the amount of revenue, profit before income tax, and income tax paid and accrued for each tax jurisdiction in which the taxpayer does...

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Maintaining Confidentiality While Navigating Cross-Border Transactions

Today, taxing authorities across the globe, including the Internal Revenue Service (IRS), are increasing their efforts to gather and share sensitive taxpayer information, often aggressively seeking copies of tax advice, opinions and analysis prepared by counsel and other advisors. In some situations, tax advisors specifically draft their advice to be shared with third parties, but frequently the IRS seeks advice that was always intended to be confidential client communications—for example, drafts and emails containing unfinished analysis and unguarded commentary. Sharing this latter type of advice could be problematic for taxpayers because such advice could be used as a road map for examiners during an audit and may mislead the IRS regarding the strength or weakness of a taxpayer’s reporting positions. Last month, we spoke to tax executives at Tax Executives Institute forums in Houston and Chicago about the IRS’s increased use of treaty requests to obtain US...

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A 360-Degree View: September and October 2017

Wrapping Up September – and Looking Forward to October Upcoming Tax Controversy Activities in October: October 12, 2017: Cate Battin, Kristen Hazel, Britt Haxton, Jane May, Sandra McGill, Diann Smith and Elizabeth Chao are hosting and presenting at the inaugural Tax in the City® event in Seattle, Washington. They will cover topics such as attorney-client privilege and the ethics of social media (CLE/CPE), recent developments around US Tax Reform, and updates on state and local tax issues for Seattle and the surrounding areas.  October 25, 2017: Todd Welty and Lowell Yoder are speaking at the TEI 72nd Annual Conference in Toronto, Ontario, and will present “Repatriation: Strategy, Practice and the Road Ahead.” November 2, 2017: Laura Gavioli, Kristen Hazel, Michael Louis, Cym Lowell, Damon Lyon, Denise Mudigere, Dave Noren, Kristina Novak, Andrew Roberson, Jay Singer, Mark Thomas and Michael Wilder are speaking at the TEI Global Tax Symposium in Houston,...

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