Tax Dispute Resolution Quarterly

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OECD & BEPS Country by country, step by step: Implementation considerations for country-by-country reporting by U.S. multinationals While the Organisation for Economic Co-operation and Development’s (OECD) project to combat tax base erosion and profit shifting (BEPS) had an ambitious agenda, the verdict on whether it will meet all its objectives remains uncertain (Read more...) 2x4 approach to country-by-country reporting Many multinational enterprise groups are already working to implement new annual reporting requirements—country-by-country (CbyC) reporting (Read more...) Post-BEPS world of permanent establishment In this May 2 article in Tax Notes International, the author discusses how the Organisation for Economic Co-operation and Development’s final base erosion and profit-shifting report on action 7 (artificial avoidance of permanent establishment status) (Read more...) © 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 568452
Country by country, step by step: Implementation considerations for country-bycountry reporting by U.S. multinationals By Thomas Herr, Raj Bodapati, and Rui Che, Economic and Valuation Services While the Organisation for Economic Co-operation and Development’s (OECD) project to combat tax base erosion and profit shifting (BEPS) had an ambitious agenda, the verdict on whether it will meet all its objectives remains uncertain. However, one very tangible impact for large multinational enterprises is clear: The requirement to file annual country-by-country reports. The authors of an article in the April 14 edition of Tax Management Transfer Pricing Report outline considerations for U.S. multinationals preparing to embark on country-by-country reporting as set forth in the final recommendations under the OECD’s project to combat BEPS, focusing on establishing a process for preparing the report, as well as analysis of the data necessary to ensure overall consistency in transfer pricing and other tax positions. 2x4 approach to country-by-country reporting By Kim Majure, Washington National Tax, and Steven Penning, International Tax Many multinational enterprise groups are already working to implement new annual reporting requirements—country-by-country (CbyC) reporting— promulgated the U.S. Treasury Department. Proposed regulations that would require certain taxpayers with annual revenue of $850 million or more to file this report are expected to be finalized later in 2016. The proposed U.S. regulations were developed in response to the guidelines issued by the Organisation for Economic Co-operation and Development as part of its base erosion and profit shifting initiative. An April 27, 2016 KPMG LLP report organizes the considerations for developing a practical approach to CbyC reporting into two main areas—tax data management and tax data and analytics—each with four steps. Post-BEPS world of permanent establishment By Kevin Cunningham, Washington National Tax In this May 2 article in Tax Notes International, the author discusses how the Organisation for Economic Co-operation and Development’s final base erosion and profit-shifting report on action 7 (artificial avoidance of permanent establishment status) would change the definition of permanent establishment and the effect that change could have on multinational enterprises. © 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 568452
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Page 3 and 4: Contents Spotlight on compensation
Page 5 and 6: Spotlight on compensation and benef
Page 7 and 8: Golden parachutes By Compensation a
Page 9 and 10: FBAR reporting: Changes are in the
Page 11 and 12: Tax enforcement trends Envisioning
Page 13 and 14: New law creates new risks for partn
Page 15 and 16: A conversation with Greg Matson—E
Page 17: 2016 webcast series Around the worl
Page 21 and 22: © 2016 KPMG LLP, a Delaware limite

Tax Dispute Resolution Quarterly

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