Daily Tax Update - November 14, 2014: European Commission Determines That Neatherlands APA Constitutes State Aid

European Commission Determines That Netherlands APA Constitutes State Aid:  Today, the European Commission published an opening decision in an investigation on whether the Netherlands’ Advance Pricing Agreement (APA) with Starbucks constitutes state aid.  In its decision, the European Commission takes the preliminary view that the APA is state aid and may not be compatible with the internal market.

Canadian Government Urges Canadian Court to Reject Challenge to FATCA Agreement:  The Canadian government asked a Canadian court to uphold the intergovernmental agreement (IGA) entered into between Canada and the United States to implement FATCA.  In the case of Hillis v. Attorney General of Canada, two Canadian citizens challenged the IGA as violating Canada’s Charter of Rights and Freedoms as well as the Canadian Constitution.  In a court filing this week, the Canadian government defended the IGA as constitutional and necessary for Canadian financial institutions and their clients.

Miscellaneous Guidance Released:
Notice 2014-73 provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates, the 24-month average segment rates, and the interest rate on 30-year Treasury securities.