Daily Tax Update - December 5, 2016: OECD Releases Additional Guidance as Part of its Base Erosion & Profit Shifting Initiative

OECD Releases Additional Guidance as Part of its Base Erosion & Profit Shifting Initiative:  Today, the Organization for Economic Cooperation and Development (OECD) released additional guidance on country-by-country reporting for multinational enterprises as part of its Base Erosion and Profit Shifting (BEPS) initiative.  The guidance addresses situations where notification to the tax administration may be required to identify the reporting entity and confirms that if such notification is required, jurisdictions have flexibility regarding the due date.

Additionally, the guidance provides that, in general, the local reporting obligations of an entity which is part of a multinational enterprise having an ultimate parent entity in the United States that makes “surrogate” filing with the United States will be satisfied by the surrogate filing.

Three Countries Added to Bank Information Exchange List:  The IRS issued Revenue Procedure 2016-56 today, adding Israel, the Republic of Korea, and Saint Lucia to the list of countries approved for automatic exchange of information on bank interest paid to nonresident aliens.  The additions are the latest step in the government’s implementation of the Foreign Account Tax Compliance Act (FATCA) to fight tax evasion.  The list was last updated in March 2016.

DTU In Depth – Phil West on International Tax

Straight Talk on Border Adjustments: What Are We Really Talking About Here?:  The election makes it more likely we will see major tax legislation enacted.  Not only has there been major tax legislation enacted relatively early in the terms of most recent new presidents, but the common control of the executive branch, Senate, and House by Republicans makes major tax legislation even more likely.  The most likely starting point for the legislation that is ultimately enacted is the June 2016 report issued by House Ways and Means Republicans (the Blueprint).  For more in-depth coverage, click here