William Byrnes

Howdy from Prof. Haydon Perryman and I of Texas A&M University.  This month we undertake a 2015 review of FATCA’s GIIN registrations relative to 2014.  We also include a chart at the end of this post…

Starbucks Manufacturing BV (SMBV), based in the Netherlands, is the only coffee roasting company in the Starbucks group in Europe. It sells and distributes roasted coffee and coffee-related products …

This month, Haydon Perryman and I review the change over the past year, and the immediate previous three months, for FATCA financial institution registrations.  The November 1, 2015 GIIN list…

Both Starbucks and Fiat represent, if one listened closely to the live press release broadcast, an first salvo by the EU Commission to establish that it has the authority, under a State Aid premise,…

William Byrnes and Haydon Perryman FATCA FFI GIIN List Monthly Update The IRS released the sixteenth FATCA GIIN list of foreign financial institutions (FFIs) that have registered with the IRS through…

On 18 September 2015 the US Treasury issued Notice 2015-66 which announced that the it intends to amend the regulations under chapter 4 (sections 1471-1474) to extend the period of time that certain…

This post answers the emails received requesting further information on the US Competent Authority, including statistics, based upon my Kluwer Tax Blog post of 25 August IRS Issues New Competent…

Haydon Perryman’s exclamation this month, in the form of the above title, underlies that the FATCA GIIN update as of August 2015 is that there is little to update in terms of new GIINs.  From July…

On August 12, 2015 the IRS released two final revenue procedures impacting the U.S. transfer pricing regime.  Revenue Procedure 2015-40 concerns the protocols and procedures for requesting assistance…