Below are several interesting authorities or publications related to international tax that have been released recently.
The U.S. Senate Permanent Subcommittee on Investigations (PSI), held a hearing on July 30, 2015 exploring the impact of the U.S. corporate tax code on foreign acquisitions of U.S. businesses and the ability of U.S. businesses to expand by acquisition. The associated report, "Impact of the U.S. Tax Code on the Market for Corporate Control and Jobs," details transactions involving Burger King, Anheuser-Busch, and Valeant.
Notice 2015-54 - Announces that the Treasury Department and the IRS intend to issue regulations under Code §721(c) to ensure that, when a U.S. person transfers certain property to a partnership that has foreign partners related to the transferor, income or gain attributable to the property will be taken into account by the transferor either immediately or periodically. This notice also announces that the Treasury Department and the IRS intend to issue regulations under Code §§482 and 6662 applicable to controlled transactions involving partnerships to ensure the appropriate valuation of such transactions.
Rev. Proc. 2015-40 - Provides guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority, acting through the Advance Pricing and Mutual Agreement Program and the Treaty Assistance and Interpretation Team of the Deputy Commissioner (International), Large Business & International Division of the Internal Revenue Service. This revenue procedure updates and supersedes Rev. Proc. 2006-54, and is being issued concurrently with Rev. Proc. 2015-41, which provides guidance with respect to advance pricing agreements.
Rev. Proc. 2015-41 - Provides guidance on the process of requesting and obtaining advance pricing agreements from the Advance Pricing and Mutual Agreement program (“APMA”), a constituent office of the U.S. competent authority, within the office of the Deputy Commissioner International, Large Business & International Division. This revenue procedure also provides guidance on administration of executed APAs.