William Byrnes

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…

Please contact us to assist in our research Prof. William Byrnes & Haydon Perryman In 2011, HMRC forecast that it would receive "billions" from the Swiss Disclosure Facility.  In 2012, HMRC stated…

Attacking Profit Shifting by Prof. Jeffery Kadet (Abstract) In recent years the financial press has turned increasing attention to MNCs that shift income to low taxed jurisdictions overseas in order…