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Ambiguities In IRS Country-By-Country Rules May Cause Woes

Law360, New York (June 29, 2016, 10:38 PM EDT) -- The IRS’ final regulations requiring multinational corporations to report financial data for all jurisdictions they operate in could lead to friction with other jurisdictions, as the rules don’t define some important terms such as fiscal autonomy or distinguish between independent contractors and employees, experts say.

The agency, which released the rules Wednesday, did clear up many concerns and adopted certain recommendations from taxpayers, including a key one to accept reports filed voluntarily before the rules go into effect in the U.S. But it declined to offer...
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