International tax

Tax authorities in various countries announced the launch of investigations after 11.5 million documents were leaked from a Panamanian law firm that specializes in setting up offshore entities.

The much-anticipated rules, under which the US would adopt the Organisation for Economic Co-operation and Development’s country-by-country reporting regime, would require reporting by multinational enterprise groups with revenue of $850 million or more in the prior annual accounting period.

The IRS has proposed to amend its regulations to limit refunds paid to beneficial owners of withheld payments to amounts actually deposited by withholding agents.

The IRS finalized temporary regulations issued in 2012, called anti-splitter rules because they aim to prevent foreign income from being inappropriately split from foreign tax in calculating the foreign tax credit.

The IRS stated that it intends to keep its Offshore Voluntary Disclosure Program open until it announces otherwise.