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TP – discussion draft includes a “Model Template of Country-by-Country Reporting” for a multinational enterprise

Jan. 30 — The Organization for Economic Cooperation and Development has released a milestone discussion draft that would require companies for the first time to complete a template providing tax administrations with exhaustive details of how they allocate their income, taxes and business activities on a country-by-country basis. Draft Template The Jan. 30 discussion draft includes […]


Malawi: Transfer Pricing Audit

The TRM team have recently advised and assisted a large MNE in interdicting the Malawi Revenue Authority from executing a faulty revised tax assessment based on unlawfully obtained documentation. The documentation was not obtained through formal Exchange of Information channels in terms of the appropriate DTA’s. TRM also assisted the MNE filing the Appeal to […]


The Top 50 Tax Payers in South Africa & TRM™ Services

In a recent tax survey by a Big 4 Firm, the list of participants noted as the 50 biggest corporate taxpayers in South Africa were listed (see full list below): TRM™ Services has either acted for and/ or educated at least 40% of the companies on this list (highlighted). For more information about our services […]


Survey of Developments – US Tax Related Reporting (Prof. William Byrnes at SAIT Conf.)

by Prof. William Byrnes. Associate Dean International Tax & Financial Services, Thomas Jefferson School of Law, San Diego, California (USA) Prof. William Byrnes delivered this paper at the South African Institute of Tax Practitioners’ Annual Tax Conference on 13 October 2010. Survey Topics Qualified Intermediary Regime (before and after UBS) (QI); Foreign Account Tax Compliance […]


RSA: Urgent Interdict Against SARS for failing to issue valid letter of findings

TRM™ is pleased to announce that it successfully represented one of the largest mining groups in the world in an urgent application again SARS in terms of which application the taxpayer sought an interdict against SARS blocking it from issuing quick revised assessments just before the prescription of the statute the three-year term under circumstances […]


KENYA: Transfer Pricing Audit

TRM™ announces that it is involved in advising a major multinational in a transfer pricing audit taking place in Kenya. The key documentation to transfer pricing in Kenya includes reference to articles 2(4) and 47 of the Kenyan Constitution, read together with the Income Tax Transfer Pricing Rules, 2006, and section 18 of the Kenyan […]


Protected: ARCHIVED LECTURES: International Tax & Tax Treaties ITX 649

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SARS LBC launches NEW special project on PAYE audits

FOR IMMEDIATE RELEASE Johannesburg, South Africa – July 27, 2010 – SARS LBC launches NEW special project on PAYE audits. SARS LBC has launched a special project targeting all LBC clients country wide, due to staffing restraints, all LBC offices and all sectors with PAYE specialists are involved in the project, thus you may receive […]


Interesting facts: From: IRS 2009-2013 Strategic Plan

“The percentage of Americans’ income originating from foreign sources doubled between 2001 and 2006.”


US Citizenship & Immigration Interpretation 318.4

Effect of claim of nonresident alien status for income tax purposes upon prior lawful admission for permanent residence. Under the Internal Revenue laws and regulations, aliens are classified for income tax purposes as “resident aliens” or as “nonresident aliens.” Resident aliens are, in general, taxed the same as United States citizens.

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