Caleb Harshberger

Washington, D.C., United States

Associate Reporter at Bloomberg Industry Group

Reporter at @tax—prev @bgov @TriangleBIZJrnl @ButlerEagle

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Articles

Trade Group Urges IRS to Nix Proposed Cloud Transactions Rule

1 week ago | news.bloombergtax.com | Caleb Harshberger

The National Foreign Trade Council is asking the IRS to withdraw the proposed cloud transactions regulations that were issued earlier this year—joining at least one other group calling for the proposed rule to be withdrawn. The proposed rule would “add significant complexity” for taxpayers, including requiring companies to create extensive new data sets for their employees in order to comply, the NFTC said in a letter issued Monday.
Business Group Asks IRS to Nix Proposed Cloud Transactions Rules

1 week ago | news.bloomberglaw.com | Caleb Harshberger

The United States Council for International Business is calling on the IRS and Treasury to remove the proposed regulations on sourcing of income from cloud transactions.
Court Cases Spur IRS Economic Substance Test Use, Official Says

1 week ago | news.bloomberglaw.com | Caleb Harshberger

Hello and welcome to this week’s Transfer Pricing Report. I was in New York this week, where NYU and KPMG held their 20th annual symposium. Transfer pricing practitioners there sparred with IRS Associate Chief Counsel for International Peter Blessing over the latest agency guidance impacting audits. In particular, practitioners complained about the IRS’s increased use of the economic substance doctrine, which the agency has said it will be applying to transfer pricing cases.
Court Cases Spur IRS Economic Substance Test Use, Official Says

1 week ago | news.bloombergtax.com | Caleb Harshberger

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Court Cases Spur IRS Economic Substance Test Use, Official Says

2 weeks ago | news.bloombergtax.com | Caleb Harshberger

An IRS official defended the agency’s growing use of the economic substance doctrine and business purpose test in tax examinations, even as practitioners say fears of the IRS applying the doctrine as a general tax avoidance rule seem to be coming true. “We have to enforce statutes that are there. We can’t ignore the statute,” IRS Associate Chief Counsel for International Peter Blessing said at the NYU/KPMG Tax Symposium Thursday.
Tariffs, Trump's Global Tax Snub Hit OECD Negotiations

2 weeks ago | news.bloombergtax.com | Caleb Harshberger

The Trump administration’s massive new tariff pronouncements, on top of its pullback from the OECD’s global tax deal, have cast doubt on the future of global tax policy efforts. Listen here and subscribe to Talking Tax on Apple Podcasts, Spotify, Megaphone, or Audible. The two-pillar OECD-led agreement seeks to create a 15% global minimum tax for large multinational corporations and change the way the companies allocate their profits among countries.
Tariffs, Trump's Global Tax Snub Hit OECD Negotiations

2 weeks ago | news.bloomberglaw.com | Caleb Harshberger

The Trump administration’s massive new tariff pronouncements, on top of its pullback from the OECD’s global tax deal, have cast doubt on the future of global tax policy efforts. Listen here and subscribe to Talking Tax on Apple Podcasts, Spotify, Megaphone, or Audible. The two-pillar OECD-led agreement seeks to create a 15% global minimum tax for large multinational corporations and change the way the companies allocate their profits among countries.
New Wave of Tariffs Sets Off Transfer Pricing Scramble

2 weeks ago | news.bloombergtax.com | Caleb Harshberger

The White House announcement of broad 10% tariffs, and much higher levies on some countries, is leading multinationals to reexamine ways they can minimize costs. The new tariffs may reverse longstanding incentives for transfer pricing and encourage companies to lower prices for goods coming into the US—with audit risks for companies that go overboard.
New Wave of Tariffs Sets Off Transfer Pricing Scramble

2 weeks ago | news.bloomberglaw.com | Caleb Harshberger

The White House announcement of broad 10% tariffs, and much higher levies on some countries, is leading multinationals to reexamine ways they can minimize costs. The new tariffs may reverse longstanding incentives for transfer pricing and encourage companies to lower prices for goods coming into the US—with audit risks for companies that go overboard.
Trade Group Weighs In on Global Minimum Tax Return Instructions

4 weeks ago | news.bloombergtax.com | Caleb Harshberger

The National Foreign Trade Council is urging the OECD to make sure taxpayers’ data privacy is protected when reporting their global minimum tax information, a letter from the group said. The group’s members are still concerned about the confidentiality of data when filing out their their GloBE Information Return, or GIR. The GIR is a standardized form companies return with their data to comply with the Organization for Economic Cooperation and Development’s 15% global minimum tax rules.