On October 9, 2015, the US Treasury Department announced that the US formally accepts deliverables from the G-20/OECD base erosion and profit shifting (BEPS) project that addresses international rules governing the taxation of company profits. According to the US Treasury Department, the Country-by-Country (CbC) Report template is expected to be very similar to what was released in the BEPS final package on October 5, 2015. It is anticipated that temporary regulations will be released to implement CbC Reports in the US for tax years beginning January 1, 2016. The announcement follows the pattern of international tax reforms (and proposals for reform) that have emerged around the world. To read more, click the link below.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...