United States

The Tax Exchange - April 2017

Treaty based residency protection only goes so far

Treaty based residency protection only goes so far

Foreign nationals who spend more than 183 days in the U.S. may face U.S. federal tax liability unless they can qualify for treaty benefits. However, while the treaty may provide protection from substantive tax liability it may not provide relief from return filing obligations.

  • April 25, 2017
State gross receipts taxes—a new trend in state tax law?

State gross receipts taxes—a new trend in state tax law?

Facing the uncertainty of federal tax reform, and in addition to widespread budget deficits and lackluster economic growth, several states are considering new (or bringing back old) methods of revenue generation.

  • April 19, 2017
Who is on first, sales tax is on second...

Who is on first, sales tax is on second...

…and nobody knows what is on third. The Abbot and Costello skit was made well before e-commerce arrived, but its focus on confusion is an apt parallel to the current state of sales tax nexus in this country.

  • April 18, 2017
EU to tighten threshold on country-by-country reporting directive

EU to tighten threshold on country-by-country reporting directive

In a recent move showcasing the EU's agenda to ensure fair taxation, the European Parliament’s Committee on Economic and Monetary Affairs proposed several potentially far-reaching amendments to the public country-by-country reporting directive. If these rules are finalized, CbC reporting could apply to smaller companies that never expected to be subject to these potential onerous reporting requirements.

  • April 13, 2017
IRS releases guidance on retirement plan matching contributions

IRS releases guidance on retirement plan matching contributions

The IRS issued proposed regulations changing the definition of qualified matching contributions and qualified nonelective contributions applicable to 401(k) plans. Although this is favorable to plan sponsors, it may be too little, too late.

  • April 11, 2017
Amazon wins the transfer pricing case against the IRS

Amazon wins the transfer pricing case against the IRS

The U.S. Tax Court ruled against the IRS and concluded that Amazon properly priced the value of certain pre-existing intangibles to be used in Amazon’s European business. This was yet another blow to the IRS and could end up costing the IRS billions in other cases if the ruling persuades other companies to continue to fight on similar issues.

  • April 03, 2017