The Council Of The European Union came to a political agreement to the mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements. All delegations in the Commission “agree on the principle that disclosure of potentially aggressive tax planning arrangements of a cross-border dimension can contribute effectively to an environment of fair taxation in the internal market and that tax authorities share the disclosed information with their peers in other Member States.”

“The Commission presented the legislative proposal with the main purpose of this initiative is to strengthen tax transparency and fight against aggressive tax planning by including into the existing Council Directive on administrative cooperation in the field of taxation (DAC) new provisions, which would require Member States to:

– lay down rules for mandatory disclosure to national competent authorities of potentially aggressive tax planning schemes with a cross-border element (“arrangements”) by the “intermediaries”    (e. g. tax advisers or other actors that are usually involved in designing, marketing, organizing or managing the implementation of such “arrangements”); and ensure that national tax authorities automatically exchange this information with the tax authorities of other Member States by using the mechanism provided for in DAC.

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Senior Tax Manager- Transfer Pricing New Jersey

Responsibilities involve a wide range of international tax matters including transfer pricing, international aspects of consolidated income tax provision, and international elements of US tax compliance. Coordinate with international finance organization regarding international audits, income tax and transaction tax compliance.  Role is responsible for providing technical tax leadership, with an emphasis on transfer pricing and international tax. Position is responsible for transfer pricing and international tax matters for the Americas consolidated group including preparation and/or review of international portions of the consolidated tax provision, preparation and/or review of international reporting requirements for the US consolidated return. Read More

This is part of the series of interviews I am conducting of highly respected tax experts and luminaries in Silicon Valley. Many of them will be speaking at the 2017 TEI – High Tech Tax Institute Conference in November. Eric Ryan is one such Silicon Valley tax luminary who was also responsible for receiving the world’s first Bilateral Advanced Pricing Agreement (U.S. – Australia). I know of Eric Ryan’s professional accomplishments since Apple Computer retained me to find him many years ago. Eric Ryan was formerly the Head of Tax at Apple Computer, a National Tax Partner/Transfer Pricing with PWC and is an international Tax Lawyer with DLA Piper, Palo Alto, CA. He understands the world of tax from all perspectives.

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Our executive search services division conducts highly specialized retained search for a sophisticated clientele. The tax opportunities listed below are some of the projects we currently have available and do not include all of our retained search projects. Many of the senior level searches we conduct are highly confidential and clients request absolute anonymity.

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Tom Kerester

Last month, the IRS updated its Transfer Pricing Audit Roadmap in recognition of the strategic importance of transfer pricing.

The IRS transfer pricing specialists in Transfer Pricing Operations (TPO) developed the Roadmap to provide the transfer pricing practitioner, whether employed in TPO or International Business Compliance (IBC), with audit techniques and tools to assist with the planning, execution and resolution of transfer pricing examinations.

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Our executive search services division conducts highly specialized retained search for a sophisticated clientele. The tax opportunities listed below are some of the projects we currently have available and do not include all of our retained search projects. Many of the senior level searches we conduct are highly confidential and clients request absolute anonymity.

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Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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Tax Jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

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William Byrnes

The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, based on taxable EBITDA. Further work on two aspects of the common approach was completed in 2016 and this is included in this update.

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Tax jobs

Looking for a tax job? Trying to kick-start your career in a new city? At TaxConnections, we try to connect you with the best tax opportunities available. The tax job opportunities listed on our website are some of the projects that are available across the United States.

Read More