Daily Tax Update - November 23, 2015: Pfizer, Allergen Agree to Merge in $160 Billion Deal

Pfizer, Allergan Agree to Merge in $160 Billion Deal:  Today, Pfizer Inc. and Allergan Plc announced that their boards of directors have unanimously approved, and the companies have entered into, a definitive merger agreement under which New York-based Pfizer and Dublin-based Allergan will be combined under Allergan and renamed Pfizer Plc.  If the deal goes through, it would constitute the largest corporate inversion to date.  The transaction is expected to close in the second half of 2016.  

OECD Releases MAP Statistics for the 2014 Reporting Period:  Today, the Organization for Economic Cooperation and Development (OECD) released statistics for the 2014 reporting period on the mutual agreement procedure (MAP) caseloads of all of its member countries and of non-OECD economies that agreed to provide such statistics.  The OECD has already provided MAP statistics for reporting periods 2006 through 2013.  According to a press release, “[c]onsidered in the aggregate, MAP inventories in OECD member countries at the end of these reporting periods show a continuous increase from 2006 to 2014, with a slight decrease in 2010.”  As part of Action 14 of the Base Erosion and Profit Shifting (BEPS) Action Plan, OECD and G20 countries have agreed to report MAP statistics pursuant to an agreed upon reporting framework. 

IRS Upgrades FATCA Online Registration System:  Today, the IRS announced in a press release that is has upgraded its Foreign Account Tax Compliance Act (FATCA) online registration system.  The upgrades include: enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number; allowing users to update their information, download registration tables and change their financial institution type; and an updated jurisdiction list.  According to IRS Commissioner John Koskinen, “[t]he registration system is the backbone of FATCA... .  These upgrades improve the FATCA process, enabling the registration of sponsored entities and making it easier for registrants to use.”


Miscellaneous Guidance:   Today, the IRS’s Large Business and International division issued three international practice units.  According to the IRS, “Practice Units are developed through internal collaboration and serve as both job aids and training materials on international tax issues.”  The practice units released today cover the following topics: penalties with respect to the failure to file Form 3520/3520-A; penalties with respect to the failure to file Form 8865; and the taxation of foreign partnerships.