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Yearly Archives: 2017

New Int'l Tax Rules May Affect US Company's Foreign Subsidiary's Treaty Benefits

On June 6, 2017 we posted More than 100 countries conclude the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS where we discussed that more than 100 jurisdictions have concluded negotiations on a multilateral instrument that will swiftly implement a series of  tax treaty measures to update international tax rules and lessen…
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More than 100 countries conclude the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS

More than 100 jurisdictions have concluded negotiations on a multilateral instrument that will swiftly implement a series of  tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises.  The new instrument will transpose results from the OECD/G20 Base Erosion and Profit Shifting Project (BEPS) into more than…
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Ending Face To Face Appeals Meeting Not a Good Idea!

On September 20, 2016, we posted No More Face to Face Meetings at IRS Appeals Division?  where we discussed that the IRS announced that effective Oct. 1, 2016, it will rarely conduct Appeals Conferences in person. More specifically, Internal Revenue Manual (IRM) 8.6.1.4, blandly entitled “Conference Practices,” provides that ALL conferences will be held by telephone…
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