EU Proposes Tax Reporting Rules for Intermediaries Including Tax Advisors

According to the new rules, the arrangement has to be reported if at least one of the indicators exists.[...]an intermediary can include those who are "reasonably expected to know" of the cross-border arrangements, which could include attorneys, accountants, as well as bankers.[...]once in...

Full description

Saved in:
Bibliographic Details
Published in:Journal of Taxation 2018-06, Vol.128 (6), p.42-43
Main Author: Hodges, Charles E
Format: Article
Language:English
Subjects:
Advisors
Disclosure
Fines & penalties
Jurisdiction
Reporting requirements
Tax avoidance
Tax planning
Taxes
Transfer pricing
Online Access:Get full text
Tags: Add Tag
No Tags, Be the first to tag this record!
Description
Summary:According to the new rules, the arrangement has to be reported if at least one of the indicators exists.[...]an intermediary can include those who are "reasonably expected to know" of the cross-border arrangements, which could include attorneys, accountants, as well as bankers.[...]once in force, intermediaries, including tax advisors, would be obligated to report the transactions to their tax authorities.A reportable transaction includes: (1) listed transactions the IRS has determined to be a tax avoidance transaction; (2) confidential transaction; (3) transaction with contractual protection, which provides the taxpayer the right to a full refund of fees if the intended tax consequences are not sustained; (4) loss transactions, which consists of transactions generating a loss under Section 165 of at least $2 million for one year or $4 million in a combination of years; and (5) "transactions of interest" which include transactions that are substantially similar to those the IRS has publicly challenged.
ISSN:0022-4863