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This month I will discuss the important topic for the anti-money laundering compliance officer, wherein the AML systems overlap with the requirement for tax compliance, and that tax compliance…

Treasury recently released its 2015 Transfer Pricing Advance Pricing Agreements Report to Congress, the seventeenth report since the initial 1999 report.  Each year, the Treasury APA Report describes…

What do these two things have in common?  Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean's Endowed Chair, Texas A&M School of Law explains In 1998, seven US heavy-duty diesel engine (HDDE)…

After a decade, the Treasury Department issued a new U.S. Model Income Tax Convention (the “2016 Model”), which is the baseline text the Treasury Department uses when it negotiates tax treaties (last…

MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors published a technical…

The IRS issued Notice 16-08 announcing that it will extend timelines or modify four elements of FATCA -  (1) modify the date for submitting to the IRS the preexisting account certifications required…

On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our friends at Wolters Kluwer (a…

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 …