FATCA: GIINs and LEIs
Musings of Professor William Byrnes with the tremendous brain power of Haydon Perryman
Firstly, a loud shout out to Haydon Perryman who crunches the IRS GIIN list into workable…
I was recently asked to analyze the often quoted figure of $150 billion lost by the U.S. Treasury to foreign non-tax compliance by U.S. taxpayers. My transcribed remarks are below. Also, see…
In a 207 page opinion the Tax Court ruled March 23, 2017 that the IRS’s adjustment with respect to Amazon.Inc's transfer pricing buy-in payment for an intragroup cost sharing agreement (CSA) is…
Lower energy cost is a major factor for U.S. manufacturers … to be able to offer on par production costs to China, and 10 percent to 20 percent lower costs than European manufacture.
I’ve been remiss…
To refresh memories, several months ago I posted part 1 of this study on Kluwer's International Tax Blog: Application of TNMM to Starbucks Roasting Operation: Seeking Comparables Through…
This month I am going to present the first part (the justification) of a Congressional proposal that I am working upon for an academic article (I will appreciate any feedback). Thereafter, Haydon…
On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here). The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA)…
William Byrnes with Haydon Perryman
This month we turn our attention to the recently revised 2016 W-8BEN-E form which has 30 parts over eight pages that can be catalogued into four sections. The IRS…
In highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters and McDonalds. I don't own Google stock. I'm not in favor of Google's near monopoly on search …
