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Treasury To Propose Foreign Tax Credit Rules For Pillar 2

by usoftax_admin | Dec 11, 2023 | Tax News

The U.S. Treasury Department announced Monday that it intends to propose regulations addressing how foreign tax credit provisions would treat certain measures under an international minimum corporate tax agreement known as Pillar Two, including requirements for...

Guide to transfer pricing and financial transactions, with an Italian nuance

by usoftax_admin | Dec 11, 2023 | Tax News

Carola Valente of Crowe Valente/Valente Associati GEB Partners explains the application of the OECD Transfer Pricing Guidelines to financial transactions as multinationals increasingly centralise their treasury functions

The India–Mauritius grandfathering clause: is converted equity eligible?

by usoftax_admin | Dec 11, 2023 | Tax News

S Vasudevan, Prachi Bhardwaj, and Loveena Manaktala of Lakshmikumaran & Sridharan explore the applicability of grandfathering clauses to converted instruments under India’s tax treaty with Mauritius

Justices Decline To Review US Trustee Fee Refund Ruling

by usoftax_admin | Dec 11, 2023 | Tax News

The U.S. Supreme Court on Monday denied the Office of the U.S. Trustee’s request for the justices to weigh in on a dispute over the proper remedy for a hike in trustee fees, which the high court previously declared unconstitutional.

Trump Cancels Plan To Testify In NY Fraud Trial Defense

by usoftax_admin | Dec 10, 2023 | Tax News

Donald Trump abruptly canceled his plans to testify in his defense on Monday in the New York attorney general’s civil fraud case, announcing the decision in a series of social media posts on the eve of his expected return to the Manhattan courtroom.

This week in tax: Ashurst guides Luxembourg to EU state aid victory

by usoftax_admin | Dec 10, 2023 | Tax News

The outcome sets a legal precedent for EU countries’ anti-abuse rules, while KPMG considers merging its Swiss and UK accounting arms
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