U.S. Crafting Protocol for Joint Audits With Treaty Partners, Shulman Says

Commissioner of Internal Revenue Douglas Shulman Dec. 10 said the United States is in the early stages of crafting a protocol that would allow it to conduct joint audits with other treaty partners, an effort that he said could include issues that now are worked out by competent authorities…

U.S. officials discuss permanent establishments in tax disputes

U.S. government officials Dec. 10 expressed dedication to a high permanent establishment threshold while revealing stepped-up efforts to find foreign taxpayers who may have created PEs in the United States…

IRS Valuation of VERITAS Cost-Sharing Deal Found to Be Arbitrary

The U.S. Tax Court Dec. 10 issued a 71-page opinion that found the Internal Revenue Service’s determination that a cost-sharing arrangement VERITAS Software Corp. entered into with an Irish subsidiary should have…

Treasury predicts major regulatory effort to implement anti-tax haven measure

Treasury Department officials said Dec. 10 that if the anti-tax haven Foreign Tax Compliance Act (H.R. 3933, S. 1934) is enacted, the government stands ready for a major regulatory effort to put it in place…

Obama To Arrive On Final Day Of Copenhagen Talks To Signal Commitment To Agreement

President Obama will arrive on the final scheduled day of global climate talks in Copenhagen Dec. 18—and not a week or so earlier as originally planned—to signal his…