Worldwide Tax Daily
quoted Peter A. Barnes
regarding a recent discussion of base erosion and profit-shifting (BEPS) limitations on deductions at the International Fiscal Association USA Annual Conference. For the complete article, please visit Worldwide Tax Daily's website
(subscription required). Excerpt taken from the article "BEPS Interest Deduction Guidance Coming" by Lee A. Sheppard for Worldwide Tax Daily.
The working group needs advice about how to do the allocation. David Hardy of Osler, Hoskin & Harcourt LLP was curious how groups filing consolidated returns would handle internal tax-sharing payments (some rules compute a separate taxable income for each member before combining). Peter Barnes of Caplin & Drysdale Chtd. worried that some members might not be average for the group or profitable. Poms understood that there could be transition issues.