“The President has directed that we investigate the effects of this legislation and determine whether it is discriminatory or unreasonable and burdens or restricts United States commerce,” Lighthizer said.
Overall, there is no evidence that Trump’s tax law spurred U.S. firms to bring intellectual property back home, Setser said, which suggests that the associated profits will continue to flow to overseas affiliates.
Voluntary disclosure of offshore accounts, financial assets and income in the run-up to full implementation of the AEOI initiative resulted in more than EUR 95 billion in additional revenue (tax, interest and penalties) for OECD and G20 countries over the
Taxpayers have several potential defenses to the accuracy-related penalty depending on the ground upon which the penalty is asserted, including “substantial authority,” “reasonable basis,” adequate disclosure,” “reasona
Based on this review and the charity’s affidavit, a qualified practitioner will be able to issue an opinion letter confirming that the charity is the equivalent of a US public charity or a US private foundation.