Mr. Cope monitors the development of U.S. tax law daily through postings on government websites, daily tax publications, monthly tax journals, tax newsletters, tax conferences and meetings of professionals organizations in New York and Washington. Each month he publishes the Tax Insights Blog, which describes and analyzes significant U.S. tax developments (e.g., judicial decisions, regulations, proposed tax legislation) having cross-border tax consequences. The blog's content should be of interest to U.S. businesses with foreign operations and businesses headquarted outside the United States with U.S. investments or U.S. operations.
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Update on Discussions on Improving the India-USA Tax Relationship
Speaking at a luncheon in Washington on November 22, 2013, Mr. Mike Danilack of the IRS updated practitioners on the current state of the relationship between the U.S. competent authority and his counterpart in India, Mr. Akhilesh Ranjan.
Differences between India and the United States on Significant Treaty Issues Continue
The U.S. tax press reports that the U.S. competent authority, Mike Danilack, while speaking at a tax conference in California in early February 2013, announced that, after consultations with his counterparts in India, he was pessimistic that India and the United States could conclude bilateral APA's given their current positions on some significant transfer pricing issues. Danilack said that India and the United States disagree on some fundamental points, including choice of transfer pricing method (cost-plus v. profit split) and the appropriate treatment of risk in a transfer pricing analysis.