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A mysterious young widow arrives at Wildfell Hall, an Elizabethan mansion which has been empty for many years, with her young son. She lives there under an assumed name, Helen Graham, and very soon finds herself the victim of local slander. Refusing to believe anything scandalous about her, Gilbert Markham discovers her dark secrets. In her diary Helen writes about her husband's physical and moral decline through alcohol and the world of debauchery and cruelty from which she has fled. This p ...
 
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show series
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress fails to pass infrastructure and budget reconciliation legislation -- House Ways & Means Committee reports out reconciliation bill with major international tax proposals -- Senate Finance Committee Chairm…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US infrastructure legislation, FY 2022 budget resolution move forward – Senate Finance Committee Chairman, members release international tax discussion draft – Finance Committee Chairman introduces bill to amend tax …
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: White House, Senate negotiators reach agreement on $1.2 trillion infrastructure package – OECD announces conceptual agreement in BEPS 2.0 project; endorsed by G20 Finance Ministers, Central Bank Governors – US, UK co…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Bipartisan infrastructure deal reached, but road to passage uncertain – House passes corporate disclosure package requiring CbC tax reporting for multinationals – Biden Administration’s proposed 15% minimum tax could…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury ‘Green Book’ offers new details on international tax proposals – Senate hearing discusses Biden Administration’s international tax proposals – House bill would require SEC regulations on CbC financial inf…
 
The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury releases President’s plan to overhaul corporate tax system – US Senators release proposed International Tax Framework – President Biden lays out $1.8 trillion American Families Plan proposal – Senate Fina…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Biden lays out $2 trillion + infrastructure plan to be paid for with tax increases – Senate Finance Committee holds international tax hearing – Congressional Democrats introduce international tax legislation…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress poised to enact $1.9t COVID relief bill with repeal of worldwide interest expense allocation – Treasury to consider reviving expired transfer pricing aggregation regulations – IRS continues APA/MAP case closu…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury Secretary says no new taxes for now, commits to OECD BEPS discussions – New final regulations address application of Section 163(j) limitation to CFCs and partnerships, reserve on certain provisions – IRS …
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress passes coronavirus stimulus and omnibus spending package, including extension of CFC look-through – IRS issues final and proposed PFIC regulations – Treasury to focus on other international projects, tax t…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Major policy changes expected following US November election – Treasury and IRS finalize regulations to reduce double taxation caused by anti-abuse rules on GILTI gap period – IRS officials provide international regul…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar 1 and Pillar 2 blueprints, invites public comments – UN releases new proposed treaty article on digital taxes – Final rules under Section 1446(f) address W/H on transfers of partnership i…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Final BEAT regulations adopt proposed BEAT guidance with some changes − New final and newly proposed foreign tax credit regulations released − Treasury issues final sourcing regulations on sales of personal property (…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS finalizes Section 245A DRD anti-abuse regulations with few changes – Treasury and IRS propose complex, taxpayer-favorable regulations to reduce possibility of double taxation caused by anti-abuse rules during GILT…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues final and proposed interest expense limitation regulations – Final and proposed GILTI regulations deliver few benefits, some surprises – IRS releases final regulations under Section 250 for computing FDII a…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Supreme Court declines to hear Altera case – US Treasury Secretary calls for ‘pause’ in BEPS 2.0 Pillar 1 discussions – USTR initiates investigations into implemented / proposed DSTs in 10 jurisdictions – IRS LB&I …
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Congress considers further action to address coronavirus pandemic – IRS finalizes proposed Section 385 regulations with no substantive changes, leaves distribution rules in effect – Treasury and IRS announce reference…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: President Trump signs interim coronavirus relief measure; attention turns to COV’ID-19 bill #4 – IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing – IRS regulations include new…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US CARES Act stimulus package to address COVID-19 has international tax implications – IRS expands 15 April tax relief and issues FAQs on extension of filing and payment deadlines, FATCA reporting – IRS issues final S…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD issues consultation document on technical design of Pillar Two – IRS issues final regulations on ownership attribution rules for CFC purposes – IRS announces Section 965 transition tax compliance campaign – Treas…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: OECD releases BEPS 2.0 Pillar One ‘unified approach’ – Treasury issues final regulations removing Section 385 documentation requirements, notice of proposed rulemaking for treating some interests as debt – IRS announc…
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Treasury announces entry-into-force for protocols with Japan, Spain, Luxembourg, and Switzerland – IRS issues proposed Section 382(h) regulations on built-in gains and losses – International TJCA guidance expected …
 
The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues proposed rules on cloud-based, other digital transactions – French President Macron comments on new Digital Services Tax – IRS increase cryptocurrency enforcement efforts – IRS will allow domestic partnersh…
 
US Senate approves amending tax protocols with Luxembourg, Switzerland, Japan and Spain – US considers retaliation against France’s new DST – IRS issues proposed PFIC regulations – IRS releases final regulations for allocating partnerships’ creditable foreign tax expenditures – IRS sending warning letters to virtual currency owners – IRS issues inf…
 
Temporary and proposed DRD regulations reflect GILTI-centric view of TCJA’s international tax rules – US government issues final and proposed GILTI and subpart F regulations – IRS issues proposed regulations under Sections 954 and 958; consequences for subpart F and GILTI regimes – IRS issues proposed regulations on FIRPTA tax exception for foreign…
 
IRS releases final Section 956 regulations, generally follow proposed rules with two major modifications – IRS finalizes certain temporary FX regulations – IRS proposed regulations under Section 1446(f) clarify scope of W/H on transfers of partnership interests – EC comments on US FDII proposed regulations – US reiterates opposition to unilateral d…
 
US Congressional tax writers concerned over unilateral digital taxation proposals – IRS publishes revised 2019 Tax Treaty Table 1 – No delay in Section 965 final regulations effective date – IRS LB&I announces new compliance campaigns on transfer pricing and information reporting – IRS may use APMA FCD Model in some exams – GAO issues report on FAT…
 
OECD holds consultation on tax challenges of digitalization, with aggressive 2020 deadline – IRS issues proposed Section 250 regulations on computing FDII and GILTI deduction – Final GILTI regulations coming by summer, PTI regs by late summer / early fall – IRS releases final FATCA regulations on compliance and verification procedures – EU comments…
 
US Treasury official comments on OECD international tax deliberations – US supports global efforts to adopt corporate minimum tax – US government may miss June 2019 deadline to finalize TCJA international regulations – Final Section 965 regulations clarify filing Form 965-A or 965-B with transfer agreements – IRS LB&I requiring transfer pricing tea…
 
Tax agenda uncertain in new Congress -- Final IRS Section 965 transition tax regulations largely follow proposed rules, but include significant changes -- IRS releases final Form 8990 and instructions -- Argentine inflation may have US tax considerations for taxpayers with Argentine operations -- OECD releases policy note addressing tax challenges …
 
US Congress fails to enact year-end tax legislation – JCT issues ‘Blue Book’ on 2017 Tax Cuts and Jobs Act – IRS issues proposed regulations on Section 59A BEAT – IRS issues proposed regulations on foreign persons’ taxable gain on sale of partnership interestes engaged in US business -- IRS issues proposed hybrid dividends / entities regulations – …
 
Congress returns for lame-duck session; year-end tax bill taking shape – IRS releases proposed regulations and related guidance on interest expense limitation under Section 163(j) – IRS issues proposed foreign tax credit regulations – IRS releases draft Form 8990, Limitation on Business Interest Expense under Section 163(j) – Taxpayers told to expe…
 
Most TCJA international proposed regulations out by year-end -- IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS announces changes to Section 965 transition tax rules affecting basis election deadline, aggregate foreign cash position -- 2018 QI, W/H foreign partnership and W/H Fo…
 
US House approves ‘tax reform 2.0’ legislation – US government issues proposed GILTI regulations – Treasury and IRS propose removing Section 385 debt/equity documentation requirements -- IRS releases draft Form 8991 for TCJA’s BEAT – IRS grants relief to RICs from Section 4982 excise tax for Section 965 inclusions – IRS to delay Section 871(m) regu…
 
US Treasury releases proposed Section 965 regulations on repatriation transition -- IRS proposed GILTI regs under review by OMB; draft GILTI and FDII forms released -- IRS announces upgrades to FATCA Registration System – US Tax Court holds upstream loan between CFCs was bona fide debt, later transfer of proceeds to US shareholders nontaxable retur…
 
US House Republicans release tax reform 2.0 framework -- IRS issues final anti-corporate inversion regulations -- Proposed repatriation transition tax regulations release imminent; Treasury official offers insights on other international projects -- IRS denies DRD to affiliated group by treating swap on stock index as SSRP regarding single issue of…
 
US Congressional leaders talk tax reform 2.0 -- US Supreme Court overturns physical presence nexus standard; major implications for sales to the United States -- IRS updates Section 965 transition tax FAQs to include late-payment penalty, filing relief -- IRS announces additional delay of Section 987 FX regulations -- US officials offer TCJA intern…
 
US officials offer insights, timelines on upcoming TCJA guidance -- House Republicans, Trump Administration discuss ‘phase-two’ tax reform -- IRS announces forthcoming regulations expanding Section 956 exception to definition of US property -- Final anti-inversion rules may be released in June – US government releases offer timing for TCJA internat…
 
Treasury, OMB announce tax regulatory review agreement – IRS notice offers some clarity on new Section 163(j) business interest expense limitation – IRS Notice 2018-26 announces anti-avoidance rules, other regulations on Section 965 transition tax – US issues CbC reporting guidance for specified national security contractors – IRS issues interim gu…
 
Congressional Republicans, Trump Administration look to ‘phase 2’ tax reform -- US opposes taxes singling out digital economy -- IRS issues FAQ guidance on Section 965 transition tax -- IRS expands ‘no TIN” list in Notice 2018-20 -- FATCA-related publications released -- IRS issues annual APA report for 2017; substantial uptick in Indian APA filing…
 
US government moving forward with TCJA international guidance, two more transition notices expected -- IRS guidance under new Section 965 prevents certain foreign corporations from making accounting period changes -- New guidelines issued for delinquent Forms 1120-F and waiver requests -- Treasury may delay Section 987 branch currency regulations u…
 
US Treasury addresses TCJA guidance -- IRS begins filling in details on TCJA’s new Section 965 transition tax on foreign earnings -- Treasury grants yet another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts -- IRS LB&I issues instructions for examiners on transfer pricing selection issu…
 
US enacts comprehensive tax reform; revamps international tax rules -- Tax accounting among top issues following enactment of US tax reform -- EU officials reviewing US international tax reform measures -- IRS issues guidance on transition tax on foreign earnings -- IRS proposed regulations may alleviate foreign currency tax asymmetries for CFCs, p…
 
US House and Senate pass competing tax reform bills – IRS concludes GRA becomes fixed on date of initial transfer – IRS may not complete planned competent authority agreements for CbCR by year end – US-Argentina tax information exchange agreement in force – IRS outlines additional international tax compliance initiatives – US to appeal ruling IRS v…
 
US Congress gains momentum on tax reform; House W&M releases reform bill – Treasury outlines future actions on international regulations under Executive Order review -- Treasury to delay application of final Section 987 regulations by one year -- Treasury / IRS 2017-2018 Priority Guidance Plan shifts focus to reducing burdens and complexity -- OECD…
 
Republican tax reform framework released; action moves to Congressional tax-writing committees – IRS offers relief for financial institutions required to obtain and report TINs – IRS issues proposed regulations on registration-required obligations and registered form rules – IRS issues updated draft APA template – OECD releases further CbCR guidanc…
 
In this podcast: 1. Jacob Heringman, 2. Francesca Torelli, 3. Paul Beier, 4. English Ayres, 5. Edward Martin and Thomas Walker, 6. Richard MacKenzie, 7. Jacob Heringman, 8. Jacob Heringman, 9. English Ayres, 10. Paul Berget, 11. Dufay Collective, 12. Paul Beier, 13. Paul Berget, 14. English Ayres, 15. Pellingmans' Saraband, 16. James Akers, 17. Duf…
 
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