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Japan's 2015 Tax Reform law delays application of exit tax provisions to foreigners for five years
The Iowa Supreme Court affirmed that Iowa's taxing scheme for natural gas does not violate the Constitution.
Colombia now imposes a net wealth tax on residents and nonresidents with net wealth exceeding certain thresholds
York City Admin Law Judge referenced the step transaction doctrine in a real property transfer tax decision
On April 28, 2015, the Treasury and IRS announced in Notice 2015-10 their intention to issue regulations impacting claims for refund or credit of amounts withheld under Chapter 3 or 4 of the Internal Revenue Code.
This newsletter covers international tax issues including legislative changes, case law and treaty changes
Maryland and Missouri's amnesty programs provide interest and penalty relief for state corporate income and other taxes
Multinationals developing and using intangibles under cost contribution arrangements should note the discussion draft.
The Australian government has released draft legislation that would amend the Australian tax consolidation regime.
The French government's new transparency measures are part of its focus on tax evasion and tax fraud.
Discusses application of excise taxes on taxable air transportation to prepaid jet cards and management fees.
Spain has approved with the agreement of the EU Commission the new Spanish special tax regime for the Canary Islands.
Recent IRS rulings have provided more clarity regarding the assets and activities that may qualify for MLP treatment.
In AM 2015-002 the IRS recently provided the most detailed guidance to date regarding the 'tax rate desparity test.'
This Month in M&A features proposed regulations which would rewrite the 'next-day rule' for consolidated return filers.
The Office of the U.S. Competent Authority released statistics on competent authority cases for calendar year 2014.
A Michigan Court made several findings regarding the application of the Multistate Tax Compact to the Michigan SBT.
The Russian Duma recently approved a bill that amends the remuneration procedure for highly qualified specialists.
Effective in 2015, North Dakota taxpayers may elect a single sales factor. Certain provisions of the Compact are amended
The IRS recently released CCA 201505038 clarifying the amount if income to be included by a lessee claiming rehabilitation
Canada's 2015 budget proposal provides payroll withholding relief for employers with temporary employees in Canada.
The past year saw a number of important developments relating to tax incentives for research.
Treasury issues proposed regulations on the PFIC exception for foreign insurance companies.
Analysis and insights into state and local tax developments
The Australian government has released exposure draft legislation for a proposed new Managed Investment Trust regime.
New rules define fiduciary by reason of retirement investment advice and outline exemptions for common transactions.
Results of the work done by economists and others under Action 11 of BEPS
The final draft of the EU's Union Customs Code was published and creates ambiguity about whether 1st sale will survive.
Updated Cayman Island AEOI Portal User Guide provides clarification on notification for sponsored FIs
In a TAM, the California FTB addresses when cost sharing arrangement payments constitute gross receipts.
On April 13, New York enacted its budget, creating several changes to the state's tax credits and incentives programs.
VAT News highlights: CJEU addresses digital publications in France and Luxembourg, GST in Malaysia, VAT in Costa Rica
Financial reporting implications of new UK diverted profits tax
Updated rules for benefit plans of exempt organizations, including 403(b) plans, 457(b) plans and defined benefit plans.
The multi-step treaty ratification process has been stalled.
Digital Goods and Services Tax Fairness Act of 2015 introduced
New York Governor signs legislation amending several provisions of the state's corporate franchise tax.
IRS applies Section 351 to amounts transferred in excess of arms-length indemnity reinsurance
PwC's Global Watch newsletter addresses important issues around income and social tax, legislation, changes in employment rules, treaties, rulings, etc. Each Global Watch is classified by the country or territory to which it pertains.
Spain: New draft TP regulations imply that taxpayers subject to the regulations will need to prepare the 'CbC report'.
Designed to help multinationals stay aware of tax accounting and regulatory developments.
Multinational enterprises (MNEs) will be concerned about the BEPS discussion draft on CFC rules
Final regulations include rules for stock-based compensation to be performance-based and exempt from deduction limits.
This newsletter covers international tax issues including legislative changes, case law and treaty changes.
With analysis and insight on policy changes around the world, these bulletins help you stay up-to-date with the latest developments and explain what these changes mean for you and your business.
New final regulations allow limited wraparound health coverage during a pilot program.
Final, temporary regs issued April 2 address allocating research credit among controlled group members.
The Spanish Tax Agency is set to strengthen their efforts in the examination of taxpayers.
BMC Software: Fifth Cir. relied on statutory construction and contractual interpretation canons in reaching its decision.
Our Tax Controversy and Regulatory Services newsletters provide analysis on significant tax controversy issues and related developments from around the world.
IRS released Rev. Procs. 2015-27 and 2015-28 modifying current correction procedures for tax-favored retirement plans.
The incentives are structured in 3 tiers.
International Tax News is a monthly publication that offers updates and analysis on international tax developments worldwide.
New York legislature approves NYC business tax reform as part of the state's budget package
US 2014 APA report indicates that IRS productivity in APAs has decreased 30 percent from 2013.
Consider the details of the discussion draft published on 31 March on disclosure of tax planning arrangements
No change in ownership when a long term lease was extended and property was then purchased by lessee and a third party.
Mississippi's dividends received deduction is unconstitutional when limited to dividends from in-state affiliates.
CCA determines captive's loss indemnification isn't insurance.
Australia has introduced into Parliament proposed amendments to taxation of employee share schemes
Oregon sales sourced ultimate destination electricity tangible
This month's issue addresses recent tax and regulatory changes in various jurisdictions.
PwC highlights significant state and local tax developments that occurred from January to March 2015.
Swiss adopted new interpretations of Circular 8 that vary from those the SFTA issued in January 2014.
Key tax issues potentially affecting companies investing in the USA today
PwC India Customs and Foreign Trade Policy Newsletter - March Edition
Bolivian TP regulations establish the concept of a related party, and the requirement to submit a TP study.
Adjustment of life insurance reserves treated as a change in basis under Section 807(f).
Dividend distributions by offshore companies to overseas shareholders therefore will not be taxable in India
Discusses a recent CCA on excise tax exemptions, and the application of the SIFL rules to multi-leg trips by employees.
The IRS LB&I division has issued guidance on whether certain activities qualify as Sec. 199 MPGE
Recent IRS and court rulings provide guidance on tax accounting issues.
China: Public Notice 16 reflects SAT's efforts to protect its tax base and overall support for BEPS initiatives.
The BEPS Action Plan discussion drafts on profit splits risk, recharacterization and special measures provide evidence of the OECD moving away from the arm's-length principle and towards formulary apportionment.
IRS Rev. Proc. 2015-25 waives eligibility requirements of Section 911(d)(1) for certain individuals living abroad.
Fifth Circuit clarifies character of losses on abandonment of certain capital assets.
Introduces significant procedural requirements for deducting certain corporate expenses
Economic power balance shifting to developing countries will impact a business's domestic and global incentives function.
The EC Tax Transparency package obliges authorities to share information on cross-border tax rulings with Member States.
India: High Court ruling provides guidance on the issue of marketing intangibles in the case of distributors
New regs provide research credit opportunity for online retailers
India has introduced a bill in parliament to deal specifically with undisclosed income and assets held abroad.
A new China Public Notice addresses outbound payments to foreign related parties.
The Cayman Department for International Tax Cooperation recently launched its Automatic Exchange of Information Portal.
PwC is pleased to release its annotated version of the 2014 Form 990.
The UK 2015 final budget provides more information on the new diverted profits tax. The DPT is effective April 1, 2015.
Taiwan Ministry of Finance amended eight articles and introduced one new article relating to TP assessment rules
Australia has released revised exposure draft legislation for the third and final element
Indian CBDT announced detailed rules explaining APA roll back provisions.
Foreign-based multinationals should be up to speed on the current US approach to international tax enforcement for several significant reasons.
Belgian tax authorities have opened a new season of TP audits and government is considering mandatory TP documentation
IRS is now accepting Cycle E determination letter applications under Revenue Procedure 2015-6.
This series provides timely analysis on emerging issues so you can stay abreast of significant tax or human resource services developments affecting your company in today's ever-changing legislative and regulatory environments. PwC's Insights is a must read for professionals wanting to stay ahead of the curve. You can customize your Insights subscription according to your interest and below listed topics.
US District Court – Constitutional claims against Delaware's unclaimed property estimation methodology survive dismissal
Tennessee – Sales tax exemption for cable customers not discriminatory against satellite television providers
Chile has extended the deadline to submit individual foreign income and related tax credit information.
Federal Marketplace Fairness Act of 2015 legislation introduced.
Describes late-2014 and 2015 agency guidance on changes to defined benefit plan reporting and disclosure requirements.
Mass., Kentucky, Maine, and NH have introduced tax haven bills while Oregon and Montana attempt to broaden theirs.
European Commission challenges France's 3% tax on dividend distributions.
Any revaluation of assets or liabilities could have Venezuelan income tax consequences.
The outcomes of the BEPS initiative have the potential to significantly impact effective tax rates, restructuring costs, and—ultimately—enterprise value and market capitalization.
VAT News highlights: 2016 VAT in Puerto Rico and GST in India, Swiss e-services, Advocate General opinion on warranties.
New tangible property guidance provides further relief to taxpayers
IRS clarifies prohibition on employer payment plans and provides limited transition relief
India's new budget imposes stricter tax compliance on assignees and may increase global mobility program costs.
Sales tax on railroad diesel fuel, when competitor purchases are exempt, could be non-discriminatory under federal act.
The Federal Injunction Act does not bar federal court review of Colorado's sales and use tax notice and reporting law.
Indian Budget 2015 was the new government's first and focuses on growth and an enabling environment.
Treasury and PBGC requested public comment on certain procedural aspects of suspension, merger and partition under MPRA.
Hong Kong's 2015/2016 budget does not introduce any changes to standard tax rates and includes rebates to taxpayers
A taxpayer was not required to include fuel surcharge reimbursements in its Texas franchise tax total revenue.
Notice 2015-16 gives a glimpse and requests comments on the excise tax on high cost employer sponsored health coverage.
Final regs allow some taxpayers to elect the alternative simplified research credit on amended returns.
Employees are crossing borders more frequently: Is your company ready to address the tax risks and obligations?
February 2015 Roundup - Recent state and local tax developments affecting retailers.
This Month in M&A features the IRS respecting taxpayer's 'self-help' measures to avoid adverse basis shift consequences.
Singapore's 2015 Budget contains a few unexpected surprises that may impact employers of globally-mobile employees.
REITs should closely monitor the proposals and determine the impact to their structure.
Discusses updated SIFL rates for the first half of 2015; and new 2015 federal excise tax rates.
Massachusetts' 5% excise tax on satellite providers did not discriminate against interstate commerce.
STC credits must be used by March 31, 2015.
New York's FY15-16 budget proposes several changes to the state's tax credit and incentive programs.
New developments provide guidance on accounting method issues
European Customs & International Trade Communiqué - January 2015
As part of our continued effort to help organizations navigate through the complexity of today's tax accounting issues, we've assembled a compilation of our Tax Accounting Services' publications released between July 2014 and January 2015.
Vol 24: Recent IRS guidance provides safe harbor accounting methods for cable system operators.
Multinational enterprises recently received additional guidance on complying with certain BEPS recommendations.
VAT News highlights: OECD draft guidelines on B2C digital supplies, import VAT deferment simplification in the EU
Michael Danilack, former Deputy Commissioner (international) in the IRS Large Business & International Division (LB&I), joined PwC's Washington National Tax Services. Michael shared his insights in an interview with Amy Elliott from Tax Analysts.
New legislative, IRS and court rulings provide guidance on tax accounting method issues
Our January edition features recent mergers and acquisition tax guidance
IRS denies immediate deduction for ceding commission in an indemnity retrocession of life insurance business
Discusses the bonus depreciation extension and a court case on substantiation requirements for use of business aircraft.
We are pleased to share PwC's 2014 Year-End State Tax Review and a Look Ahead to 2015 and Beyond— a brief, interactive summary and collection of Insights focused on the key developments, issues and trends across the state and local tax landscape in 2014 and what we may expect for 2015 and beyond. There was one striking truth about the state and local tax world in 2014: It continued to offer a rich mix of legislative, judicial and administrative actions that altered the state tax landscape.
Recent developments on Section 199 and other IRS guidance shed light on tax accounting method issues.
MNEs may be concerned about various aspects of the six Discussion Drafts released last week as part of BEPS
VAT News highlights: HMRC and VAT pension schemes, digital tax audit files in France, real time VAT reporting in Spain
Temporary & final regulations, Second Circuit affirmation: the Barnes Group Tax Court case, and a 'retroactive CTB' CCA.
This month's issue addresses recent tax and regulatory changes in various jurisdictions
Tax-related identity theft is an increasingly widespread problem for both business and individual taxpayers. PwC's Beth Tucker explores the risks, effects, warning signs, and how business taxpayers can minimize their chance of becoming a victim.
Global Tax Accounting Services Newsletter (October-December 2014)
Discusses spousal accompaniment on business aircraft and use of business aircraft by executives in the holiday season.
Key tax developments for global companies operating in the US.
Recent legislative developments and IRS guidance shed light on tax accounting method issues
This month's issue addresses recent tax and legal changes in various jurisdictions including Austalia, China, Greece
Our November edition features proposed partnership distribution regs, the first significant issue ruling and other recent guidance.
Our overall view of the PwC partners surveyed is that it provided some useful indicators of the approaches being taken.
Discusses a year end review of the use of business aircraft and the outlook for potential legislation.
On 21 November 2014, the OECD released a Discussion Draft on 'Follow Up Work on BEPS Action 6: Preventing Treaty Abuse'
The IRS is moving towards 'cooperative compliance' in interactions between the IRS and taxpayers, and have updated their process for Information Document Requests for multinational companies.
PwC's 2015 year-end guide to tax and wealth management offers guidance for strategic tax planning, managing your portfolio, charitable giving, estate and gift planning, business succession planning and other topics.
New BEPS discussion draft regarding Chapter VII of the OECD Transfer Pricing Guidelines on low value services.
Affordable Care Act, 'first sale' strategy, and doing business in the US
The impact of technology on unclaimed property.
This Bulletin summarizes the newly released OECD discussion draft on permanent establishments.
This month's issue addresses recent tax and legal changes in various jurisdictions.
This edition of International Tax News includes updates on the OECD BEPS initiative and EU State aid.
This bulletin considers how tax authorities in many countries are streamlining tax processes for cross-border employees.
Our October edition features: The IRS intends to issue regulations under section 7874 to address 'inversions.'
The European Commission takes new action regarding State aid rules, this time involving Spain.
Discusses recent cases on substantiating business use of aircraft and application of passive activity rules to leases.
Accounting Methods Spotlight: Recent legislative developments and IRS guidance impacting tax accounting method issues
This briefing on EU State aid answers common questions and answers
The OECD published on 16 September 2014 a report on hybrid mismatches that was was approved by G20 Finance Ministers.
This issue of PwC's European Customs & International Trade Communiqué covers EU sanctions against Russia and more.
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These alerts provide analysis of the impact of major transfer pricing, tax, and related developments within hours of the news breaking, authored by PwC professionals around the world. Each alert is classified by the country or territory to which it pertains.
A quarterly periodical that provides updates on significant federal and state tax developments or issues that affect individuals, estates and trusts.
China's State Administration of Taxation released new rules regarding offshore indirect equity transfers.
This Insight is the third in a series addressing how to get started implementing the IRC Section 501(r) final regs
The IRS released final forms and instructions used to comply with the new ACA information reporting requirements
The US and Kazakhstan have announced that fiscally transparent entities may benefit from the countries' tax treaty.
IRS concludes that S corporation AAA balance expires after post-termination transition period
This reform could affect multinationals (MNCs) doing business in Venezuela.
Sweden has issued guidelines on withholding obligations of foreign employers with a permanent establishment in Sweden
On January 22, 2015, S.B. 118 was introduced in Hawaii to remove the dividends paid deduction for REITs in the state.
Penalties often arise are when a business's employees exercise nonqualified stock options or restricted shares vest.
New United Kingdom rules change the social security treatment of employment-related securities for mobile employees
The Belgian Constitutional Court has asked the European Court of Justice for a ruling on the Belgian fairness tax.
The House Ways and Means Committee today voted to permanently extend and modify the Section 41 research credit
Final FTC splitter regs address where taxpayers claim FTCs for foreign taxes paid on income not yet subject to US tax.
The President's budget includes both new and recurring proposals affecting employee retirement and health benefits.
This Tax Insight summarizes the US inbound-specific proposals in the Budget.
Treasury's 'Green Book,' released February 2, 2015, outlines the Administration's Budget proposals for fiscal year 2016.
The IRS has released guidance providing safe harbor accounting methods for tangible property costs of cable systems.
Insurance tax provisions in Obama's FY 2016 budget.
The Social Security Agreement between India and Norway has entered into force providing benefits to mobile employees.
FATCA brings significant implementation challenges to industrial products and services multinational companies.
Transfer of property under a 100% coinsurance transaction may be treated as a tax-free exchange.
House Ways and Means Committee today voted to permanently extend expired tax provisions
The IRS on January 16 issued two new revenue procedures that update the procedural rules to change an accounting method.
Release of Paying Taxes 2015, joint study by PwC and the World Bank Group, comes at pivotal time for tax policy.
President Obama on February 2 submitted an FY 2016 budget that reaffirms his support for 'business tax reform'.
Distributions to owners of pass-through entities ruled to be included in San Francisco's payroll expense tax base.
Spanish tax reforms to Corporate Income, Personal Income, Non Resident Income and Value Added Tax Act have significant impact.
The key question for US tax policymakers is whether 2015 will be marked by compromise or gridlock.
The IRS on January 16 issued two revenue procedures that update rules to change an accounting method for tax purposes.
The proposed IUS regulations are comprehensive and reflect thoughtful consideration of many complex issues.
IRS issues final regulations with respect to foreign financial assets that do not significantly alter previous guidance.
The IRS today released proposed regs addressing various issues regarding the treatment internal-use software.
The implementation of FATCA has required changes to the existing information reporting for MNCs
President Obama recently signed a law extending the research credit through December 31, 2014.
The Senate late on December 16, 2014 voted 76 to 16 to pass H.R. 5771, the Tax Increase Prevention Act of 2014.
FinCEN on December 10, 2014 issued Notice 2014-1 to further extend the filing date of FBAR
US Department of the Treasury provides FATCA relief to jurisdictions with IGAs treated as in effect.
Charitable diversions: Tax implications and tips for addressing them.
In September, the Internal Revenue Service (IRS) released drafts of the 2014 Form 990, Schedule H and instructions.
Rev. Proc. 2014-54 provides automatic method change procedures for taxpayers to comply with the final disposition regs.
How are budget constraints in the IRS affecting affecting enforcement strategies? What options are available for resolving tax controversies?
Securitas Holdings, Inc. v. Commissioner: Tax Court allows a deduction for premiums paid to a captive insurance company
The IRS will not contest a restaurant's use of a facts-and-circumstances method to allocated kitchen labor to COGS
Paul DeNard recently spoke with Tax Analysts about his career, the interaction between the domestic and international sides of Large Business & International tax, and his thoughts on the audit selection and personnel challenges facing the Service.
Cencast employment tax decision impact on production companies and employees, REIT rulings and CA film tax credit.
Recently, the OECD published reports on the BEPS Action Plan items dealing with topics relevant to the PLS industry.
California expands and extends its film credit.
Recently released instructions to the 2014 Form 1042-S clarify FATCA reporting requirements for US premiums.
Treasury and the IRS recently issued Notice 2014-52 addressing certain cross-border business combination transactions.
The IRS on August 14 issued final regs that restate and clarify the computation of certain ending inventory values.
A pre-filing agreement (PFA) allows a taxpayer to obtain certainty on an issue before filing its return.
The IRS on August 14 released final regulations regarding disposition of tangible depreciable property.
IRS provides annual domestic asset & liability percentages for foreign insurance companies.
IRS concludes that life insurance company's passive investment activities qualify as insurance business.
The 2014-2015 Priority Guidance Plan includes seven items specific to the insurance industry.
Under the Sec. 263A regs, taxpayers may allocate some royalties to COGS or between prop. sold and ending inventory.
There are areas where it was not appropriate for UK CDOT to exactly mirror US FATCA due to differences in context.
BCBS reorganization ruling includes representation regarding 9010(a) health insurer fee.
In our August 2014 issue, we explore state and local tax issues affecting retailers.
Global Information Reporting: OECD publishes long anticipated Commentary on Common Reporting Standard.
The IRS recently published final regulations allowing filers of certain information returns to use truncated TINs.
IRS directive addressing hedges of variable annuity guarantees.
Final regulations prohibit taxpayers from using identified mixed straddles to recognize built-in capital gains.
Wyden criticizes Treasury and IRS for failure to close hedge fund 'loophole' that uses offshore insurance companies.
Global Green Policy Insights is a bimonthly update on the latest developments in environmental taxes, regulations, and other "green" policies around the world. Written by PwC specialists around the world, they provide timely updates on new tax incentives, credits, and policy issues of interest to multinational organizations.
The IRS recently released the instructions for Form W-8BEN-E for complying with FATCA.
Spectrum auction, Favorable REIT rulings for EMC companies, New York State Corporate Tax Reform.
IPCC's new climate change report; EU's new State aid guidelines; Highlights of country-specific developments
According to our 2014 Assessing tax, average ETRs over the last three years have continued to edge upward.
Taxpayers transferring goods or property between group members must consider Sec. 263A impact on intercompany profit.
IRS Notice 2014-39 clarifies important questions with regards to Treasury Section 1603 grants subject to sequestration.
Financial executives at major organizations are increasingly collaborating with their tax departments and monitoring the expanded use of enforcement actions by the Internal Revenue Service under stricter guidelines for complying with information document requests (IDRs).
Support payments made by manufacturers under 'facility image upgrade programs' are includible in gross income.
Assessing Tax 2014 provides a detailed analysis of tax rate metrics for 324 companies and highlights tax trends for aerospace and defense, automotive, chemicals, engineering and construction, industrial manufacturing and metals, and transportation and logistics companies. This issue includes a special report on the surge in international tax controversy.
The EPA released proposed regulations under the Clean Air Act that would for the first time set carbon emissions reduction targets for existing US electric power plants.
FATCA not only impacts the financial services sector, but many entities outside of the traditional financial services sector with operations in and outside of the US.
With the credits and incentives landscape always changing, this publication on C&I developments will help you stay abreast of issues that may affect your business.
In Revenue Ruling 2014-15, the IRS holds that an arrangement entered into to provide health benefits for retirees of a single employer qualifies as insurance.
New York tax reform contains important tax benefits applicable to manufacturers, some of which are effective in 2014.
The US Treasury and IRS announced in Notice 2014-33 that 2014 and 2015 will be a transition period for IRS enforcement and administration with respect to FATCA.
The PwC Retail and Consumer Roundup - Recent state and local tax issues affecting retailers (April 2014).
This article highlights the Top 10 accounting method changes for pharmaceutical companies.
FATCA and other recently issued US information reporting regulations are effective immediately or apply beginning July 1, affecting many nonfinancial services entities.
Covered entities are required to report their net premiums written information for calendar year 2013 to the Internal Revenue Service by April 15, 2014.
ECJ A-G deems green energy law flawed; China to cut energy intensity further; India to set up environment regulation authority; new Indonesia policy promoting renewables.
IRS expands when a jurisdiction will be treated as having an IGA in effect and extends to May 5, 2014 the time by which FFIs must register with the IRS.
On 3/31/14, the Mississippi governor signed Senate Bill 2933, which provides a new method of apportionment for certain major pharmaceutical and medical product suppliers.
Entertainment, Media, and Communications Tax Newsletter: Vol 21. OECD Action Plan on BEPS and its impact on EMC Companies and more.
Manufacturer not required to capitalize construction support payments made to its retailers.
Insurance tax provisions contained in the Obama Administration FY 2015 Budget Proposal.
The IRS issued final regulations relating to the adjustment to inventory costs for the receipt of certain sales-based vendor allowances, specifically vendor 'chargebacks.'
Treasury and the IRS recently released the last substantial package of regulations necessary to implement FATCA, with varying impacts to insurance companies.
The final IRS regulations provide companies the option of allocating capitalizable sales-based royalties to property sold, or between property sold and ending inventory.
House Ways and Means Chairman Dave Camp released the 'Tax Reform Act of 2014' discussion draft, which would affected Insurance companies dramatically.
Treasury and the IRS recently released FATCA amendments and coordinating regulations.
C Corporations may continue to claim enhanced inventory donation deductions
The US Treasury and the IRS released on February 20 final and temporary regulations for FATCA and coordinating regulations for Chapters 3, 4 and 61.
The OECD recently released the Common Reporting Standard to establish a new global standard for automatic exchange of financial account information.
We explore many state and local tax issues affecting retailers, including a Colorado sales tax credit opportunity and Nebraska's proposed daily sales tax remittance law.
In this issue, we concentrate our state tax credits and incentives review to an in-depth exploration of the new and expanded provisions of certain New York credits.
There are many potential tax risks, obligations, and costs associated with moving employees abroad for foreign assignments.
In Validus Reinsurance, Ltd. v. U.S., the DC District Court held that the insurance FET does not apply to certain retrocession arrangements.
This Tax Insight serves as a high-level primer of information reporting and withholding requirements for 2014 and beyond.
Warsaw Climate Change summit (COP19) summary; EU carbon targets for 2030 and a new OECD report; less emphasis on supporting renewables and greater concern over pricing.
Rent-A-Center, Inc. v. Commissioner: A divided Tax Court allows a deduction for premiums paid to a captive insurance company.
PwC's Washington National Tax Services (WNTS) offers a preview of the key tax policy issues facing the Obama Administration and Congress
IRS insight into the Convenience Kit rules and the interpretation of exportation and importation of medical devices and the contract manufacturing rules applied to MDET
Soon to be released 'Common Reporting Standard' promises new FATCA-type obligations around the world.
A listing of PwC webcasts hosted by the US Tax Services team.
Calendar year 2013 has seen considerable activity across the global legislative and regulatory landscapes. We have seen changes to tax laws in several key territories, and certain legislative trends having a significant impact on income tax accounting. These developments, combined with an environment of economic uncertainty, have added to the challenges in accounting for income taxes.
On December 26, 2013, the IRS released the final FFI agreement (to implement FATCA) which contains a number of changes and clarifications to the draft FFI Agreement.
Entertainment. Media & Communications tax newsletter: Section 199 Benefits & Burden determination, communications company tax complexity, goodwill in radio station swaps
For tax years beginning on or after January 1, 2014, retailers will need to evaluate the impact of these new regulations on their businesses.
The IRS concluded that a taxpayer was not entitled to deduct cash bonuses paid to employees until the end of the year in which the bonuses were actually paid
The IRS has issued loss payment patterns and discount factors and salvage discount factors applicable to accident year 2013
Pharmaceutical and Life Sciences ("PLS") companies have traditionally set their transfer pricing strategy by trying to manage the expectations of multiple external stakeholders (regulatory bodies, income tax authorities, and customs authorities) and by staying abreast of industry trends. Nowadays, this task has become even more complex given the recent developments in the international tax and transfer pricing environment and the attention allocated by the media to the international tax practices of multinational companies. This news alert addresses some of the key highlights of the draft documents published by the OECD in the recent months and their anticipated impact for PLS companies.
UN report on climate change; Chile, Portugal, France and Poland renewable energy; developments in the biofuels market; emission in the aviation sector
The IRS issued a proposed update and revision of the revenue procedure governing advance pricing agreements (APAs).
This decision should be of interest to companies that recently have litigated (or may litigate) issues in the Tax Court.
This release follows the international tax reform discussion draft and tax administration reform discussion draft.
This release, the second in a series of staff tax reform discussion drafts, follows the November 19, 2013 discussion draft on international tax reform.
The changes made by the Updated Directive should allow more taxpayers to streamline the examination of their Section 199 deductions.
The Finance staff international reform discussion draft ('discussion draft') proposes to repeal or modify the current deferral system.
Australian Treasurer has issued a media release regarding the fates of previously announced but unlegislated tax measures.
Summarize the new guidance and the impact on foreign investors doing business with India through an entity located in Cyprus
The IRS issued Notice 2013-69 addressing FFI agreements and related issues under FATCA and accompanying regulations.
On October 22, 2013, the START-UP NY program will create tax-free zones to attract and grow new businesses, and incentivize existing businesses, in New York.
The final regulations are intended to ease the administrative burden and complexity of the segregation rules for loss corporations with small shareholders.
The Japanese government recently announced that it will proceed with a planned increase in the consumption tax rate from 5% to 8%, effective April 1, 2014.
The tax accounting items on the new business plan cover a wide range of transactions and therefore should be of interest to many taxpayers.
Missouri bad debt deduction sales tax; New Jersey incentives; New York City commercial rent tax; deductibility of management fees
On October 11, 2013 the Chancellor announced that the UK and Isle of Man had signed an automatic tax information exchange agreement based on FATCA (the US Foreign Account Tax Compliance Act). This Newsbrief provides an update and background information on the agreement.
The sequestration rate applicable to Treasury Section 1603 grant programs will be 7.2%.
This Insight discusses the 2013 proposed regulations.
Chairman Camp has reaffirmed his commitment to plan to overhaul the US tax system in time for a markup in the fall.
China, South Korea, Thailand plan to subsidise solar power; India and the UK plan to support wind energy; and France is increasing its support for biogas power
This quarterly publication discusses critical tax legislation and regulatory developments that may impact entertainment, media and communications companies.
This newsalert summarizes those provisions in the circular that could affect foreign investors in India.
An account receivable established under Rev. Proc. 99-32 may constitute increased related-party indebtedness for purposes of the related-party debt rule
In this issue, our authors explore two different avenues that states may take to offer incentives to businesses.
Discusses in depth the recently issued final regulations regarding the deduction and capitalization of expenditures related to tangible property
Companies that have sold assets which were used to generate FSC commissions or ETI exclusions may be able to restore a portion of the basis of these assets.
Regulations on the exception from the definition of 'qualified research' for internal-use software under Section 41(d)(4)(E).
New guidance for companies beginning construction in 2013 on renewable electricity projects that qualify for the production tax credit.
Tax Court held that the amount of carried loss reserves claimed by an insurance company under Section 832 was fair and reasonable
This Newsbrief describes key changes contained in the technical correction and provides observations.
This is the first in a three-part series that will discuss the recently issued final regulations regarding the deduction and capitalization of expenditures.
Twenty one guidance projects addressing consolidated return issues or other issues relating to corporations and their shareholders.
The IRS released final tangible property 'repair' regulations regarding the deduction and capitalization of expenditures related to tangible property.
IRS announced in Notice 2013-56 that it would be providing penalty relief for incorrect name and taxpayer identification number combinations reported.
IRS concluded that the post-death beneficiary of five annuity contracts could exchange the value of those contracts tax-free for higher payouts.
Newly proposed Section 174 regulations address several long-standing issues related to the deduction for research or experimental (R&E) expenditures
The new regime applies to a wide range of companies across all industries, including industrial products and services companies.
Efforts to advance tax reform legislation move into a critical phase this fall.
On August 29, 2013, the IRS released a new Form W-9, Request for Taxpayer Identification Number and Certification and its instructions. The Form W-9 is one of several forms being revised to conform to the provisions of FATCA. This Newsbrief provides an overview and key observations of the new Form W-9.
IRS has provided domestic asset/liability percentages and domestic investment yields for foreign insurance companies.
Geosyntec Consultants, Inc. v. US, US District Court ruled that research conducted under fixed-price contracts held not 'funded,' eligible for research credit
Insights exploring unclaimed property, credits and incentives, and state income tax reporting for retailers.
On August 14, 2013, HM Treasury and HMRC issued updated Guidance Notes ("UK Guidance") in respect of the Implementation of The International Tax Compliance (United States of America) Regulations 2013 ("UK Regulations") laid before the UK House of Commons earlier this month.This version of the guidance supersedes any versions previously published. This Newsbrief identifies key changes and certain additions from the draft UK Guidance released in May 2013.
This publication discusses key tax and financial reporting considerations of patent box regimes and other technology incentives.
Deductions for policyholder dividends did not satisfy the 'all-events' test under the principles of Section 461.
The Internal Revenue Service (IRS) announced the opening of the Foreign Account Tax Compliance Act (FATCA) registration system on August 19, 2013. This Global IRW Newsbrief provides background information, important deadlines, key observations, and next steps.
Retailers may have a time sensitive opportunity to qualify for current enterprise zone benefits before the credits expire at the end of 2013
New Mexico and Virginia have enacted special state income tax rules for retailers
Key observations from HM Treasury and HMRC's release of the International Tax Compliance (United States of America) Regulations 2013 to improve international tax compliance and implement FATCA.
Understanding its impact and the path forward for nonfinancial multinational businesses.
These procedural changes are intended to make it easier for FBAR filers to use the e-filing system.
IRS directive for use in determining whether a taxpayer has the benefits and burdens test for purposes of Reg. sec. 199
Final regulations explaining the exception for certain expenditures paid or incurred under a reimbursement or other expense allowance arrangement
The IRS has released guidance (Notice 2013-51) on the procedural requirements related to the branded prescription drug fee ("the fee") for the 2014 calendar year. This annual fee, which applies to companies that manufacture or import branded prescription drugs, was enacted as part of health care legislation in 2010 and applies to each calendar year beginning after 2010. For 2014, the aggregate amount of the fee that is to be allocated proportionally to covered entities is $3.0 billion.
The IRS issued temporary and proposed regulations addressing identified mixed straddle transactions.
China and the United States both launching initiatives in recent months to reduce greenhouse gas emissions and drive sustainable growth.
General overview of elections and accounting methods
The IRS recently issued guidance regarding the deferral of gross income in connection with certain advance payments received from the sale of gift cards.
China and the Netherlands recently entered into a new double taxation agreement (DTA) and protocol.
The monograph provides an overview of developments affecting the taxation of insurance companies in 2012.
Tax code provisions offer relief to taxpayers affected by disasters.
The Obama administration decision to delay reporting and enforcement of employer mandate is welcome relief for all employers that would have been subject to the reporting requirements and shared responsibility payments. Pharmaceutical and Life Sciences companies will now have additional time to determine their coverage responsibilities and to implement the necessary recordkeeping and reporting capabilities.
OECD published an Action Plan that addresses the perceived flaws in the international tax rules that were discussed in the BEPS report
The latest edition of Continuing Developments in the Taxation of Insurance Companies from PwC reviews developments affecting the taxation of insurance companies, with a special focus on legislation, tax accounting, and Federal, international, and multi-state taxation developments.
Australia has enacted new loss carry back rules that will give Australian companies the option to carry back tax losses to a preceding tax year.
CA AB 93 and SB 90 make sweeping changes to the California Enterprise Zone credit program
The IRS recently issued a directive to all LB&I employees that should improve the way that they, and taxpayers, deal with Information Document Requests.
Additional year before the mandatory employer and insurer reporting requirements under the Affordable Care Act
CA AB 93 replaces most of the current program with a new hiring credit, a new sales and use tax exemption, and a negotiable tax credit for certain investments
PLR 201323009, the IRS granted an insurance company an extension of time to file an election to be subject to the alternative tax under Section 831(b)
Rev. Proc. 2013-32 will restrict the scope of letter rulings issued under sections 332, 351, 355, 368, and 1036
MO S.B. 287 allows for sponsored captive insurance companies and respective protected cells to be organized and operate in the state
Senate Finance Committee Chairman Max Baucus and Ranking Member Orrin Hatch issued a letter to all Senators setting forth next steps
This quarterly publication discusses critical tax legislation and regulatory developments that may impact entertainment, media and communications companies
Senate Bill 1133 was introduced to permanently extend the New Markets Tax Credit
Litigation between the IRS and Wells Fargo over access to tax accrual workpapers has been resolved by the trial court.
The IRS has recently released drafts of certain FATCA-related forms.
Understanding the effects of the European Commission's proposed amendments to the automatic exchange of information ("AEOI") between EU Member States.
The IRS concluded that a written collaboration agreement constituted a partnership for all federal income tax purposes.
This Newsbrief identifies key changes from the draft UK Regulations released in December and highlights relevant aspects of the associated Guidance Notes.
Chinese State Administration of Taxation has clarified how local-level tax bureaus should assess beneficial ownership
This Newsbrief provides an overview of the key elements of the German-U.S. IGA and how it compares to the Model 1 IGA.
Emissions trading, carbon tax, carbon markets, carbon price support, renewable energy, cleantech, subsidy, environmental policy, landfill tax, climate change
A memorandum directing LB&I staff to not challenge the treatment of certain 'eligible milestone payments' paid in the course of a covered transaction.
The Neal Bill would limit deductions for reinsurance premiums paid by a US insurance company to its foreign affiliates.
Permits taxpayers to elect to treat certain dispositions of a target corporation's stock as a sale of the underlying assets of the target corporation.
The IRS concluded that minimum royalties paid for the use of licensed patents must be capitalized to ending inventory under Section 263A.
The Australian 2013 – 2014 federal budget, released on May 14, contains a number of measures aimed at increasing Australian tax revenue.
Determining whether expenditures to maintain, replace, or improve steam or electric power generation property must be capitalized under Section 263(a).
The House Ways and Means Committee May 8 held a meeting covering the work of certain of its 11 bipartisan working groups on tax reform
The RCF case confirms that it is possible to look through an LP to identify the relevant taxpayer for purposes of applying a tax treaty.
LB&I recently issued a memorandum for all staff regarding the treatment of eligible milestone payments paid or incurred in the course of certain transactions.
JCT staff today issued a 568-page report on 'Present Law and Suggestions for Reform Submitted to the Tax Reform Working Groups'
The IRS concluded in a field attorney advice (FAA 20124401F) that minimum royalties paid for the use of licensed patents must be capitalized in part to ending inventory under Section 263A.
Pharma and Life Sciences Tax News, Vol.12, No. 6: IRS disallowance of research credit for employee separation payments validates importance of documentation - 30 April, 2013
Important guidance for entities that are classified as FFIs under FATCA and considering applying for qualified intermediary, withholding foreign partnership, or withholding foreign trust status.
A taxpayer can meet the special rule for government contracts under Section 199.
The IRS provided applicable guidance implementing both a physical work standard and providing an economic safe harbor.
A recent PLR permitted the taxpayer to claim 'bonus depreciation' by filing Form 3115, Application for Change in Accounting Method.
US District Court concluded a policyholder had basis in the shares of stock received in connection with the demutualization of five life insurance companies.
A provision that limits deductions for reinsurance premiums paid by a US insurance company to its foreign affiliates.
The IRS recently issued a memorandum for all LB&I staff that provides direction to field examiners on the repair versus capitalization issue.
President Obama's FY2014 budget proposal includes a permanent extension of the production tax credit and would make the credit refundable.
The President's budget asks Congress to "immediately begin the process of reforming the individual and business tax systems."
Form 8957, when issued in final form, may be used by foreign financial institutions (FFIs) to register for FATCA purposes.
Minimum royalties paid for the use of licensed patents must be capitalized to ending inventory under Section 263A.
Planning and development activities did not constitute a MPGE activity for purposes of the Section 199 deduction.
The UK Chancellor of the Exchequer delivered his 2013 Budget on March 20, 2013. The Chancellor reinforced the message that the United Kingdom is 'open for business'.
Payments to certain salaried employees pursuant to a 'voluntary separation program' do not constitute 'wages' eligible for the Section 41 research credit.
In this Newsbrief, we take a closer look at the potential impact of FATCA on the global captive insurance market.
To accelerate use of these credits, an election must be made under Section 168(k)(4).
Development activities held not Section 199 manufacturing activities
There could be a change to the country's thin capitalization regime.
This quarter, our authors explore the benefits, pitfalls, and opportunities of some of the the state and federal tax credits.
The Senate Budget Committee on a party-line vote approved an FY 2014 budget resolution. Senate Finance Committee announced upcoming meetings.
House Budget Committee Chairman Paul Ryan (R-WI) today released a proposed FY 2014 House budget resolution.
House Ways and Means issued a 'small business' tax reform discussion draft that features proposals affecting large and small partnerships and S corporations.
The exchange by an irrevocable trust of one life insurance policy for another qualifies as a like kind exchange.In PLR 201304003, the IRS concluded that the exchange by an irrevocable trust of one life insurance policy for another qualifies as a like kind exchange under section 1035.
The IRS issued Notice 2013-19, which clarifies deficiency reserves.
IRS released AM 2012-010, a GLAM addressing application of the end-of-the-day rule and the next-day rule of Reg. sec. 1.1502-76(b)
Treasury announced that all awards made under the Treasury 1603 cash grant program will be reduced by 8.7 percent.
Amendment that would change the evidence required to prove tax residency
The budget would defer the introduction of general anti-avoidance rules to April 1, 2015.
The Australian government recently introduced draft amendments to the Australian general antiavoidance rules.
The regulations provide guidance on the key issues that arise when options or convertible partnership interests are issued to investors.
Read this PwC tax insight on new temporary tangible property regulations for general asset account treatment of property subject to Section 168.
The excise tax for offshore medical device manufacturers in Puerto Rico has been set to 4% for taxable periods from January 1, 2013 until December 31, 2017.
The Discussion Draft proposals would most significantly impact taxpayers that execute financial transactions as part of a trading or investment strategy.
The OECD released a related 90-page report, Addressing Base Erosion and Profit Shifting.
Repayment to the DRS is due by February 14, 2013.
The taxpayer had a zero basis in the shares it received as part of a demutualization.
Yesterday, the IRS announced that a second round allocation of $150 million in tax credits will be available for advanced energy manufacturing property.
Companies with manufacturing operations in Puerto Rico (PR) are subject to an excise tax on goods or services provided to offshore-related entities under Act 154 of the Internal Revenue Code. The excise tax is imposed in lieu of the PR income tax that otherwise would apply as a result of the source rule.
Companies that meet certain requirements may elect to pay an alternative tax provided in Section 831(b)
This WNTS Insight will provide updates on important treaties and protocols between the United States and key countries in Europe, Asia, and South America.
The US Department of the Treasury and the Internal Revenue Service provided welcome relief on a number of key issues for the asset management industry.
The final regulations follow last February's release of the proposed regulations.
State assumed interest rates and applicable federal rates for the determination of reserves under Section 807(d) for insurance products.
COP18 UN climate change summit, carbon markets, carbon law, carbon price support, bilateral carbon offset, renewable energy, cleantech, environmental policy
Foreign taxpayers who paid cascading insurance excise tax evaluate filing protective refund claims
The protocol is significant since it provides for exclusive residence State taxation of interest.
Key international tax law changes that could affect US multinational corporations (MNCs).
IRS Large Business and International (LB&I) Commission issued a directive not to challenge qualified research expenditures (QREs) claimed by taxpayers in the pharmaceutical sector during Stage 1 (discovery and preclinical stage) or Stage 2 (clinical trial stage) of the pharmaceutical development process if the taxpayer provides a Certification Statement regarding those QREs.
Related to the insurance industry, these final FATCA regulations contain a number of significant differences from the proposed regulations.
500 pages of guidance in the form of final regulations to implement the provisions of the Foreign Account Tax Compliance Act (FATCA)
House Ways and Means Chairman Dave Camp released for public comment a discussion draft on reforming the tax treatment of financial products.
Final regulations were issued along with a press release on January 17, 2013
The Indian Finance Minister recently announced the government's intent to accept several of the committee's GAAR proposals.
President Obama signed the American Taxpayer Relief Act of 2012 (the Act) which freezes tax rates and retroactively reinstates certain business tax incentives that expired such as the research and development (R&D) tax credit for pharmaceutical and life sciences companies. This Alert provides guidance on accounting for the retroactive reinstatement of the R&D tax credit.
American Taxpayer Relief Act of 2012 extends the research credit for two years and resolves an issue regarding the treatment of qualified research expenditures
A new whitepaper from PwCs cross isciplined Global Information Reporting practice.
Companies now should consider whether to elect general asset account (GAA) treatment for their historic depreciable property.
Proposed regs to implement and expand the application of a voluntary IRS pilot program that permits filers to truncate taxpayer identification numbers (TINs).
The previous deadline of June 30, 2013 has been extended to June 30, 2014 for eligible officers and employees to file their 2010, 2011 and 2012 FBARs.
American Taxpayer Relief Act of 2012, retroactive extensions through 2013 of certain business and energy tax provisions that had expired.
Renewable and alternative energy provisions, including a one-year extension of the production tax credit for wind energy and a one-year extension of bonus depreciation.
The bill extends certain expired and expiring business and individual tax provisions through the end of 2013.
Mass. economic development incentive program, R&D credits, jobs incentives programs
We have prepared this report to assist management teams to identify and understand the areas most frequently commented on by the SEC.
Congress is set to recess for Christmas without a 'fiscal cliff' agreement to avoid scheduled tax increases and spending reductions
This quarterly publication focuses on critical tax legislation and regulatory developments that may impact entertainment, media and communications companies.
These modifications should make the program more appealing to employers and enhance options for employers.
The IRS published regulations amending the temporary regulations to delay the effective date.
The IRS revoked an earlier ruling allowing taxpayers to include the value of facility-specific PPAs in the depreciable basis of the project.
LB&I issued a memorandum regarding examination of section 41 research credit claims in the pharmaceutical sector.
OECD recently issued several updates and consultations relevant to transfer pricing that could have important consequences for multinational enterprises.
The IRS has postponed certain tax filing and payment deadlines for affected taxpayers located in a designated disaster area.
The Chinese Ministry of Commerce recently promulgated final regulations regarding capital contributions of equity interests.
The IRS on November 30 issued proposed regulations concerning the net investment income tax under new section 1411 of the Internal Revenue Code
Section 199 domestic manufacturing deduction does not apply to a taxpayer that repackages and labels pills that it did not manufacture
The IRS has issued loss payment patterns and discount factors (Rev. Proc. 2012-44) and salvage discount factors (Rev. Proc. 2012-45) applicable to accident year 2012.
The Supreme Court overruled a Sixth Circuit presumption of vesting in collectively bargained retiree health benefits.
CBSA Changes Valuation Adjustment Policy
2015 Italian Budget introduces several tax law changes relevant to multinational companies.
Some aspects of the new tax that South African interest payers and foreign recipients should consider before March 1.
Democrats have re-introduced bills to curb perceived abuses involving cross-border mergers and low-tax jurisdictions.
CBSA Announces Phase 1 2015 Audit Priorities - What they Mean for Importers
Several new laws introduce significant amendments to the Ukrainian Tax Code.
Employers may be liable to employees for failing to collect FICA taxes on deferred compensation on a timely basis.
Korea's Supreme Court: payments to use patents registered outside Korea for domestic use is not Korean-source income
VAT News highlights: ECJ addresses VAT groups, UK MOSS scheme, priority refunds in Italy and IMMEX companies in Mexico.
Tax policy bulletins provide analysis and insight on policy changes around the world and what these changes mean for you.
Discusses aircraft related items in the current IRS business plan and the requirement to use the SIFL rules consistently.
Accounting Methods Spotlight: New developments provide guidance on tax accounting method issues.
This Month: The IRS Business Plan, lists upcoming guidance that will affect corporate & partnership transactions.
Global companies investing in the United States face unique opportunities and challenges. Doing business in the US reviews the key tax issues and provides insights to help investors navigate the US business environment.
For foreign-based multinational corporations (MNCs) doing business in the United States, the amount of customs duties paid on goods entering the U.S. often is not a top-level consideration. However, many of those companies might be leaving money on the table by paying more in customs duties than is necessary.
Joel Walters, leader of the U.S. inbound tax practice and the global communications tax practice at PwC shares insight on the overall tax environment, public perception of multinational companies and the OECD/G-20 BEPS project.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on the continually changing HR landscape and what organizations need to do to take control of today's opportunities and tomorrow's decisions.
Explore mandatory tax reporting rules, EU rules for banking, extractive and logging industries, plus US implementation & country-by-country reporting issues.
In the current economic environment, the priority for governments worldwide – and Western governments in particular – is for their tax systems to generate the level of revenues they expect. This focus is reflected in a strong public sentiment that everyone should 'pay their fair share'. Inevitably, 'everyone' is often defined in popular parlance as large corporations. And asked whether corporations are paying their fair share of tax, growing numbers of people appear to believe – rightly or wrongly – that the answer is "no".
PwC US Tax Leader, Mark Mendola recently spoke with Tax Analysts contributing editor Jeremiah Coder on tax uncertainty, accounting firm services, and future tax policy.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on Total Rewards, and delve into the challenges employers face of getting their employees' "total rewards" packages right.
Over 1,300 CEOs talked to us about their global talent management issues. The results of these conversations are reflected in this report.
In this release we discuss a variety of accounting and reporting developments and the related tax accounting considerations.
TP to Go is a new mobile application from the PwC global transfer pricing network that brings the best thought leadership from the network directly to your current smart phone. TP to Go is free to download on iOS, Android, and BlackBerry.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders. In this issue of HR Innovation, we focus on Healthcare for Employers, and bring to light where the opportunities and obstacles might lie post-health reform and where different paths might lead.
This publication is focused on the topics we believe will be most relevant to the preparation of 2012 year-end financial statements.
In this special edition of PwC's Perspectives, Anthony Curtis and Ogniana Todorova from PwC US take a detailed look at transfer pricing in Africa.
In this release, we discuss decisions of the International Financial Reporting Interpretations Committee along with other accounting and reporting developments.
On November 8, a group of PwC Global Structuring Partners facilitated an engaging discussion with a group of senior tax professionals on a range of issues impacting the way multinational corporations align global structures to manage their US tax burden.
Learn how and why BRIC countries have made strides as manufacturing and services countries and are now developing into significant end markets for multinationals.
HR Innovation offers advanced thinking about the challenges that should be uppermost on the minds and agendas of organizations and their Human Resources (HR) leaders.
This report looks at the challenges that companies across the world are facing as a result of stringent and diverse transfer pricing requirements.
PwC and the National Association of Stock Plan Professionals (NASPP) are pleased to announce the release of the 2012 Global Equity Incentives Survey (GEIS): "Back to the Basics"— Executive Summary. Our survey is one of the most comprehensive studies available on the design and administration of equity incentive compensation plans for multinational companies.
Our Tax policy Perspectives series provides insight into specific topics influencing global tax policy developments, including in-depth analysis of trends in specific jurisdiction. Drawing on case law, practical experience, and knowledge of tax systems worldwide, we'll provide a global perspective on each subject area, look at how it is currently playing out in a few contrasting territories and suggest the pivotal challenges to come.
Our tax policy trends publication provides analysis and insight into the key global trends influencing the development of tax policy worldwide.
Trends in multinational businesses, unremitted foreign earnings, and recent regulatory trends
This newsletter discusses a recent update to the financial accounting convergence projects and other accounting and reporting developments along with the related tax accounting considerations.
PwC's M&A Asian Tax Guide summarizes jurisdictions of the Asia Pacific area and highlights key tax issues relevant to purchasers and sellers of the mergers and acquisition transaction.
This report provides messages for companies with existing Swiss HQs which are seeking to expand their scope, assure their sustainability or reduce costs, for companies planning to implement a centralised business model but also for the Swiss authorities.
In this release, we discuss some recent updates to the financial accounting convergence projects and other tax accounting developments along with the related tax accounting considerations.
Goodwill impairment testing continues to be a challenging and complex area of practice. As companies perform goodwill assessments, tax considerations can play a critical role in the final conclusions.
This PwC reference guide helps you manage your financial services transfer pricing issues.
Key areas of focus when accounting for income taxes during interim periods
Accounting for income taxes 2011 year-end hot topics
As part of their current workplan, the SEC is analyzing the impact of IFRS on US issuers and whether, when, and how to incorporate IFRS into the US financial reporting system.
This issue of HR Innovation looks at current trends and their implications for meeting organizational goals while cultivating and sustaining an efficient, high-performing workforce in a dynamic organizational culture.
The impact of transfer pricing in financial reporting
2011 Global Equity Incentives Survey: The Rise of Performance-based Equity
Information on corporate and individual tax rates and rules in over 150 countries worldwide.


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Every Day we post 10 new Classical CD and DVD reviews. A free weekly summary is available by e-mail. MusicWeb is not a subscription site. To keep it free please purchase discs through our links.
MusicWeb - The
International Web Site Founder: Len Mullenger [UK], Classical
Editor: Rob Barnett [UK], Regular Reviewers: Steve Arloff [UK],
Guy Aron [Australia], Tony Augarde [UK], Terry Barfoot [UK], Melinda Bargreen [USA], David J. Barker
[Australia], Rob Barnett [UK], Nick Barnard [UK], Robert Beattie [UK], Dave
Billinge [UK], Peter Bright [UK], Byzantion [UK], Colin Clarke [UK], Dominy Clements [Netherlands], Michael
Cookson [UK], Hubert Culot [Belgium], Evan Dickerson [UK], Gavin Dixon [UK], Robert J. Farr [UK], Christopher Fifield [UK], Göran
Forsling [Sweden], John France [UK], Patrick Gary [USA], Pierre Giroux [CAN], Paul C. Godfrey [UK], Michael Greenhalgh
[UK], William Hedley [France], Gary Higginson [UK], Neil
Horner [UK], Robert Hugill UK], David Jennings [UK], Bill Kenny [UK], William S Kreindler [USA], Ian Lace [UK], Em Marshall-Luck [UK], Oleg Ledeniov [USA]Rob Maynard
[UK], David A McConnell [USA], Kirk McElhearn [France], Robert McKechnie [UK], Ralph Moore [RMo] [UK],
Dan Morgan [UK], Margarida Mota-Bull [UK],
Glyn Pursglove [UK], John Quinn [UK], Carla Rees [UK], Brian Reinhart [USA],
Donald Satz [USA], Mark Sealey
[USA], John Sheppard [UK], George Stacy, Kevin Sutton [USA], Bert Thompson [USA], Simon Thompson [UK], Zane Turner
[Australia], Steve Vasta [UK], Johan van Veen [Netherlands], Raymond Walker
[UK], Derek Warby [UK], Brian Wilson [UK], Jonathan Woolf [UK] Leslie Wright
[USA]. A complete list
of contributors can be seen here
MWI How
to find articles on MusicWeb Review
Indexes Book
Reviews Interviews
CD reviews Records
Of The Year Monthly
Best Buys Comment
Scowcroft's Garlands Classical
blogs Reviewers
Logs Reviewers
Resources Film
Music (Archive)
Notes External
sites PotPourri
MusicWeb International thank
Naxos for the no-strings use of their server to mount the website. |

subset: commoncrawl


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Product Details
Isuzu Ascender 2004, 282 Series Stainless Steel OBDII Round Catalytic Converter (2820125) by Flowmaster®, 2.5" Inlet / 2.5" Outlet. 16" Length. 5" Width. Includes Heat Shield. The new Flowmaster replacement catalytic converters are made to meet and exceed all federal environmental regulations and, as all Flowmaster products, to deliver the best possible performance. The shells are made of stainless steel, and the catalytic components meet or exceed the legal requirements.
Fits Following Models:
- Isuzu Ascender Limited / LS 4.2L
- Isuzu Ascender S Federal Emission
Note: Flowmaster Replacement Catalytic Converters are not available for sale or use on vehicles registered or operated in the state of California.
- Exceed all federal emission standards
- Stainless Steel shells
- High load of noble metals in substrate for reliable performance
- Efficient gas flow
- 25000 mile emission compliance warranty on internal components
- 50000 mile/5 year warranty on exterior casings
Flowmaster, the masters of performance mufflers and exhaust systems since 30 years, have decided to also offer street legal, high quality, replacement catalytic converters to the market. The catalytic converters are engineered for long life and reliable performance. When you install a Flowmaster Catalytic Converter you avoid the irritation that low quality converters can cause by frequently lighting up the MIL symbol on your dash, requiring equally frequent service appointments to check the codes and make the relevant adjustments. The Flowmaster converters are engineered and built in the U.S.A., using only first grade materials, to the high quality standard required to get the Flowmaster trademark stamped into the casing.
The outer shells are made in stainless steel of the highest automotive grade. The interiors of the converters feature strata that carry catalytic substrates with high loads of noble metals, making sure that the converters perform to exceed the USEPA standards. The strata themselves are of OEM or higher quality, ensuring that they last and can endure the vibrations and stress even in hard driving conditions. As Flowmaster is the master of gas flow, you can also rest assured that the exhaust gases flow through the converters with minimum possible restrictions for maximum possible performance. If and when you need to replace your catalytic converter, get a converter with the Flowmaster stamp. There is no better.
Flowmaster® has its roots in solving the engine noise problems encountered by California racers in the 1980s. In 1983 Flowmaster's founder, Ray Flugger, created his first patented design of racing silencers, which dampened noise with minimal loss of power. Ray attached handles to ease carrying the square shaped race mufflers through the race pits, and the mufflers became known as the "suitcase mufflers." Today, the innovative Flowmaster mufflers are the result of years of development with top race engine builders, thousands of hours of dyno research and "real-world" on-track testing.
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You will never pay more with CARiD! Not only will we match prices from any competitor's website or other reputable source, we will continue to honor that promise for up to one year after your purchase.
We'll match the price at time of purchase, or refund you the difference if done after the purchase. Either way, we are totally committed to providing you the best online shopping experience.
We're car and truck enthusiasts, just like you! And it's enthusiasts we hire in our Sales and Service Centers. Many of our staff are ASE certified and have spent years in the retail auto business.
We conduct our own in-house training, and we even bring vendors to us for hands-on product training demonstrations. You're getting true expertise when you phone or email us!
With hundreds of vendors, and tens of thousands of components for sale, we put tremendous effort into coordinating our data with our vendors' data in order to guarantee that you get the correct part.
Our huge database is regularly cross-checked to keep it current and optimized. At times, our thoroughness makes our data even more accurate than our suppliers! This rigorous process means that you can always order with confidence.


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Following a�very busy Thanksgiving week for moviegoers, ticket sales dried up like that last bit of turkey you still have in your fridge.�The Hunger Games:...
Usually, when the name�Amanda Bynes�is used in the same sentence as Twitter, it's time to brace...
DELAWARE, Ohio – The 51st annual Ohio Wesleyan University President's High School Band Festival will be held Jan. 17, 2015, providing...
Girl meets boy; girl loses boy; girl gets boy back again: it's a simple, easily extrapolated formula for great story telling. For example, boy has superpowers; boy loses superpowers; boy gets superpowers back again. Or, lightly summarizing one...
STATE - The United States Attorney's Office for the Middle District of Pennsylvania announced today that Senior United States District Court Judge...
Senate President Pro Tempore Joe Scarnati (R-25), Senate Majority Leader Jake Corman (R-34), Senate Majority Appropriations Chairman Pat Browne (R-16)...
James Franco�was the man of the hour on�
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for PCP in Honesdale
Experienced only need apply
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The Senior Living Community At Bethany Village is now accepting applications for the following positions:
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There were no Scrooges to be found at the festive opening night celebration of A Christmas Story, The Musical, the new Broadway show based on the classic 1983 holiday favorite. Hear what the cast and creators had to say about this merry new musical!
"Wicked" original cast member Idina Menzel sings "The Wizard and I"
January 20, 2010The star of Honeymoon in Vegas spends an afternoon painting with Susan Blackwell while talking about sh*tting his pants, singing Wildhorn and more.
April 3, 2015Lerner and Loewe's classic musical Gigi is Broadway-bound! We talked to Vanessa Hudgens, Corey Cott, Victoria Clark and the cast about the reimagined revival, which opens at the Kennedy Center in January.
December 22, 2014Get a taste of the national tour of The Book of Mormon.
September 1, 2013Original "South Pacific" cast member Matthew Morrison sings "You've Got to Be Carefully Taught"
January 28, 2010The cast of "The Phantom of the Opera" sings "Masquerade"
January 22, 2010Learn how to do the rip-roaring Newsies paper dance on Broadway Balances America.
November 2, 2014Scenes from the well-loved musical, now playing at the Minskoff Theatre.
March 18, 2010Watch video clips of Helen Mirren as Queen Elizabeth II in The Audience on Broadway.
March 9, 2015The Lion, the Witch and the Wardrobe's Catherine Fowles talks about the new stage adaptation of the classic children's book and why this off-Broadway fairy tale is bringing folks back to "the bare essentials of imagination."
April 3, 2013The Fantasticks tells the story of a young boy and girl who fall madly in love at the hands of their meddling fathers, but soon grow restless and stray from one another.
July 28, 2009


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Offers approachable good looks inspired by the latest in interior design.
Durable design utilizes the parts that have proven so reliable in Life Fitness equipment around the world.
Minimal adjustments mean exercisers can complete their workouts efficiently and quickly.
Graphic placards identify adjustment points and correct setup, reducing potential intimidation.
Weight stacks are located close to the exerciser, enhancing comfort.
Optional full shrouds protect the weight stack system from everyday debris.


text:
Had a great time once again. The YMCA had a family night, so we had lots of spectators peering through the windows at us.
Unfortunately Paul couldn't make it last night, but everyone else was there. I brought a little outboard plastic kit and ran around before gettting down to business and running the Boone. Dave and George worked on trimming and getting their Gatos to run pretty good. Larry had the reliable tug, and Patti ran the Cobra. Don was trimming out the Albacore. I think we gave them a good show!
Dave took some video of my Boone running fairly tight circles in the deep end of the pool. Hopefully he can post them up here today.
Can't wait till next month.


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Rockies' 11-run fifth highlights rout of Mets
DENVER -- Down by four runs in the fifth inning, after hitting a weak grounder so routine most players would save their effort on the basepaths for their next at-bat, the Rockies' Eric Young ignited an eruption that turned into an 11-run frame during an 18-9 rout over the Mets.
Friday night's series opener featured a solo shot, a pair of three-run homers and a grand slam for the Rockies, but arguably the biggest at-bat came from Young, who pinch-hit to lead off the fifth, scored two runs in the inning and turned the tide for Colorado.
Young ran full speed for first on a comebacker, and Mets starter Chris Schwinden's throw to the bag was high and outside enough for Young to go in low, reaching safely under the attempted tag. Young then stole second and advanced to third on catcher Mike Nickeas' throwing error.
"Every time I hit the ball, I run hard," Young said. "Have you ever seen me not once run hard? It's the right way to play the game."
Though he's played primarily off the bench this season, Young has turned himself into a devastating weapon, capable of reaching base any time he hits the ball on the ground and wreaking havoc once he does get on base.
"I saw the first baseman starting to reach up and to his left," Young said of his changing course on the fly. "I knew to try and get as far away from him as I can. Getting down on the ground was the best way to do it. As soon as I saw him start going up, the first thing that clicked in my head was, 'Go down.' He never touched me. It would have been too hard. He's reaching high and to the left and he's trying to go all the way down to the ground."
The Rockies followed Young's hustle play with three walks, seven hits (including two three-run homers from Carlos Gonzalez and Dexter Fowler), and a hit batsman, along with four errors from the Mets, to score 11 runs, one shy of the Rockies' record for runs in an inning. Gonzalez set a club record with five RBIs in the inning, as the Rockies sent 15 men to the plate.
"You play enough games here, you know innings like that are going to possibly take place," Mets manager Terry Collins said. "It happened pretty fast."
And it happened as a result of Young's speed on a play that clearly energized his club, having just fallen four runs behind in the top of the inning.
"That's great that it happened like that," Young said. "Play hard and hopefully it rubs off. Right afterwards, everybody else started stretching out hits and going first to third. The aggressiveness seemed to heighten."
The rally salvaged a good effort by starter Drew Pomeranz, who pitched four innings and left the game with tightness in his left forearm. The game was tied when Pomeranz exited, but Esmil Rogers gave up four runs in one inning of relief, putting the Rockies behind, 6-2, heading into the breakout bottom of the fifth.
"I was kind of mad that my forearm tightened up on me," Pomeranz said. "I felt great out there. The changeup was good today. Everything was good today. I had a few walks in there, but I was making good pitches, and a lot of their hits were broken bats that found a hole somewhere. But I felt great."
Pomeranz first felt the stiffness during his warmups before the fourth inning, but the left-hander was able to get through the frame, although he did give up a home run to Scott Hairston.
"It was just a little tightness," Pomeranz said. "No serious pain. Obviously, if it was serious pain, I wouldn't have been able to pitch that inning and get people out."
The ball continued to fly, as the Mets put three runs back on the board in the top of the sixth on Hairston's two-run double off the left-field wall and an RBI single up the middle from Duda. The double completed a cycle for Hairston, who singled to lead off the second, homered to lead off the fourth and tripled in the fifth. It was the 10th cycle in Mets history.
Despite Pomeranz's strong start and the Rockies' big offensive output, Colorado's bullpen still got a workout. Seven of the Mets' runs came off Rogers and Josh Roenicke. Matt Reynolds, Matt Belisle, and Rex Brothers finally brought the scoring to an end with three scoreless innings to finish the game.
The Rockies had five batters with multihit games, including Marco Scutaro (four), Gonzalez, Todd Helton and Fowler (three) and Troy Tulowitzki (two).
Ramon Hernandez came to the plate in the seventh with the bases loaded as the only Rockie starter without a hit -- even Pomeranz singled in the second -- and deposited a 1-1 fastball into the right-field seats for his seventh career grand slam and the Rockies' first of the year.
"Our ballclub is capable offensively, and explosions like that can occur," Tracy said. "Carlos had six RBIs [matching a career high]. You get a big at-bat from Dexter. You get a grand slam from Ramon Hernandez. You get a [solo shot] from Troy Tulowitzki. Just up and down -- four hits from Scutaro. A phenomenal offensive game that began in the fifth inning with an extraordinary hustle play by Eric Young Jr."
Owen Perkins is a contributor to MLB.com. This story was not subject to the approval of Major League Baseball or its clubs.


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A new study finds that knee replacement surgery may raise a person's risk of gaining weight, says a Reuters News article based on a study published in Arthritis Care & Research.
For this study, lead investigator Daniel Riddle, PT, PhD, FAPTA, and his group used a patient registry from the Mayo Clinic in Rochester, Minnesota, which collected information on 917 knee replacement patients before and after their procedures.
The researchers found that 5 years after surgery, 30% of patients had gained at least 5% of their weight at the time of the surgery.
In contrast, fewer than 20% of those in a comparison group of similar people who had not had surgery gained equivalent amounts of weight in the same period.
Riddle's team said that this degree of weight gain can lead to "meaningful effects on cardiovascular and diabetes-related risk as well as pain and function."
One possible explanation for the counter-intuitive results, experts said, is that if people have spent years adapting to knee pain by taking it easy, they don't automatically change their habits when the pain is reduced, reports Reuters.
"After knee replacement we get them stronger and moving better, but they don't seem to take advantage of the functional gains," said Joseph Zeni, PT, PhD, a physical therapy professor at the University of Delaware, who was not part of the study. "I think that has to do with the fact that we don't address the behavioral modifications that have happened during the course of arthritis before the surgery."
Part of the explanation for the weight gain could be the age at which patients get surgery. People in their 50s and 60s tend to gain weight, anyway. Still, in light of the lower rates of weight gain in the comparison group, which was also middle aged and older, Riddle said something else may also be at work.
In fact, the team found that patients who had lost weight before their surgery were slightly more likely to gain weight afterwards—perhaps because when people lose weight in anticipation of an event, such as surgery, they are more likely to put it back on after they're achieved the goal, says the article.


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The Town of Lockport's prime retail corridor might get a new look by as soon as late next year.
The town has applied for Federal Transportation Enhancement Program grants that will be announced soon. If the town gets the grants, it will undergo a major streetscaping project
The idea is to add medians, crosswalks, different street lighting and landscaping in the Transit North Historic Canalway Corridor and Dave Kinyon of the Town of Lockport IDA says this might only be the start.
He says those improvements could lead to more retailers.
"We see the opportunity to use the streetscape project to help leverage another $30 million in private sector investment," Kinyon said. "Our analysis indicates the ability to generate another roughly 570 jobs when this is fully built out."
Kinyon added that the grants for the streetscaping will be announced this fall, and that would mean design work would get underway next year and construction on the project could start in late 2014 or 2015.


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Top Definition
When the excessive body mass of some "large" person falls on you in a way that said mass molds around some portion of your body.
You see that bitch who feel on me? She fatted <--(fat(verb)) my leg like a mf. I could almost feel her clogged arteries bulgin'.
作者 Adamfier


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Super Beast Imitating Drawing
this wiki
Super Beast Imitating Drawing [1] | |||
320px | |||
Name | |||
Kanji | 超獣偽画 | ||
Rōmaji | Ninpo:Chōjū Giga | ||
Literal English | Super Beast Imitating Drawing | ||
Viz manga | Art of Cartoon Beast Mimicry | ||
English TV | Ninja Art: Super Beasts Scroll | ||
Games | Ninja Art: Beast Scroll Replicas | ||
Debut | |||
Manga | Chapter #283 | ||
Anime | Naruto Shippūden Episode #33 | ||
Movie | Naruto Shippūden 2: Bonds | ||
Game | Naruto Shippūden: Gekitō Ninja Taisen! EX 2 | ||
Appears in | Anime, Manga, Game, Movie | ||
Data | |||
Classification | Ninjutsu, Fighting Style | ||
Rank | B-rank | ||
Class | Offensive, Supplementary | ||
Range | All ranges | ||
| |||
A technique characteristic to Sai that allows him to adapt to the circumstances of any confrontation. The ninja uses chakra-infused ink to quickly draws objects onto his scroll. The moment the brush is removed, the images leap from the paper, grow to life-size, and act according to the user's will. Because they are made of ink, a single blow is usually enough to dispel them. For discreet communiques while undercover, Sai is able to turn the words he writes into small animals, allowing them to travel unnoticed to the intended target, after which the ink animal requires a scroll to reverts back into written information.[2] Few techniques rival it in terms of versatility.
[show]List of Drawings
The strongest feature of this ninja art is its ability to create various effects based solely on the user's ingenuity.
- Mice
- Useful for tracking or searching, and often created in large number. By not taking roads to travel, the "mice" are inconspicuous, making them the most suitable, not just for searches, but also for delivering information obtained from enemy camps to Konoha. Furthermore, if one draws a countless number of mice, it even becomes possible to perform an unworkable number of searches.
- Lions
- For attacking from a distance, lions can be drawn. They are usually created in small groups to attack foes directly.
- Birds
- If it's necessary to do reconnaissance from the sky or travel in high-speed, large birds can be drawn and ridden. Smaller birds can also be used to carry explosive tags and for long-distance or urgent information delivery. Sai can also quicly draw a bevvy of these smaller birds and lead them against the enemy.
- Owls
- Used in Naruto Shippūden 2: Bonds.
- Leeches
- Used as a low damage projectile-like attack. Larger and heavier leeches can also be drawn.
- Bats
- These drawing can morph into a makeshift umbrella, or attach themselves to the enemy's face and blind them.
- Fish
- Useful in delivering messages in water.
- Snakes
- After being drawn quickly, the "snakes" can be used as ropes to restrain someone. With the ability to soundlessly enter through even the smallest crevice, they can also be used for assassination purposes.
- The Benevolent Kings (仁王, Niō) or Vajra Strongmen (金剛力士, Kongō Rikishi)
- Two powerful, gigantic beings, Agyō (阿形) and Ungyō (吽形), are used to physically attack the enemy with their great strength.
- Explosive Tags
- These can be created with ink and attached to small birds, allowing the user to bombard the enemy from the air.[3]
- Tiger
- Used in his Sealing Technique: Tiger Vision Staring Bullet.
- Cats
- Used in Sai's Day Off.
- Squirrels
- Used in Sai's Day Off.
- Rabbits
- Used in Sai's Day Off.
- Dragon
- Used in Power - Episode 1
This technique is in reference to the Chōjū-jinbutsu-giga (lit. Animal-person Charicatures), or Chōjū-giga for short, a set of four picture scrolls belonging to the Kōzan-ji Temple in Kyōto, Japan and sometimes credited as the first manga. The scrolls depict various anthropomorphic animals dancing and playing about in a lively ceremony, which seems to be the basis for Sai being able to animate his own drawings for various purposes.
- According to Sai, this technique does not work as well in rain.[4]
- In Rock Lee no Seishun Full-Power Ninden, Rock Lee was able to paint mice with the head of Might Guy. Tenten painted a large, "cute", humanoid bunny and panda bear. Sai still had to perform the technique to animate their drawings.


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Rangers, Astros enter rivalry series at opposite ends
Keuchel returns to Houston rotation for opener vs. Ogando
The Astros and Rangers share a state and now a division, but the two franchises don't have much else in common these days.
The Rangers, who have been to two of the past three World Series, once again lead the American League West. The Astros are firmly entrenched in a rebuilding phase.
So it follows that Texas is 16-4 against Houston since the beginning of the 2010 season, including taking two out of three at Minute Maid Park to begin '13. The teams will meet for another three-game set in Houston, starting on Friday night, with the Rangers' Alexi Ogando facing off against the Astros' Dallas Keuchel.
"They're young, they're inexperienced and they're learning on the job," Rangers manager Ron Washington said of the Astros, who are 10-25 through Wednesday. "What you see comes from learning on the job at the Major League level. Sometimes you have to take a whipping. I was on the Twins in 1981-82 when we took a whipping. Five years later, that group in 1987 won the World Series."
The Astros just took two of three from the Angels following a six-game losing streak, winning back-to-back games for only the third time this year. Washington believes the franchise is headed in the right direction.
"They know the process and they believe in their kids," he said. "They're going with the kids and staying with the process. They're not panicking and they don't care what other people are saying. That's what you've got to do. They're doing what they need to be doing. They know the situation they are in. It's no secret. But you read things out of Houston, it's all positive. That's a good thing."
After a win at Milwaukee on Wednesday, the Rangers are 1-2 on their current four-city, nine-game road trip.
They will hand the ball to Ogando, who tossed 6 1/3 scoreless innings at Houston on April 3, giving up four hits, walking one and striking out 10. The right-hander (3-2, 3.08 ERA) has not notched more than five strikeouts in any of his six starts since then, but he owns a 2.84 ERA over his past three outings and held the Red Sox to one run in six innings on Saturday.
Keuchel (0-1, 4.96 ERA) will be making his first start of the season after six appearances out of the bullpen. Coincidentally, the lefty's first start of last year -- and the first of his career -- also came against the Rangers. On June 17 in Arlington, he gave up one run on four hits over five innings.
Keuchel went 3-8 with a 5.27 ERA in 16 starts a year ago, but with Houston struggling to find quality starting pitching, he will get another shot at the role.
"I'm a starter at heart," Keuchel said. "If my role is in the bullpen, then it's in the bullpen. I'm going to try to pitch to the best of my ability. Friday is going to be no different."
Rangers: Happy to see you
Several Rangers have enjoyed playing against the team's in-state rival over the years. Chief among them is former Astros star Lance Berkman, who owns a .460/.526/.860 batting line against Houston, with five home runs and 18 RBIs. During a 15-game Minute Maid Park hitting streak that goes back to his final three contests with the Astros in 2010, Berkman is hitting .491 with six homers and 23 RBIs. He also has drawn 10 walks over that span, with a .567 on-base percentage and .912 slugging percentage.
"I like hitting there," Berkman said. "It's definitely a comfortable place for me. I spent the majority of my career there, so when I go back, I feel right at home."
Ian Kinsler is hitting .327 with 10 home runs and 25 RBIs in 41 games against the Astros, and his .624 slugging percentage is his highest against any AL club. His 45 runs scored are the 14th most by an active player against Houston, but he is the only one among the top 50 with more runs scored than games played.
Among the other Rangers who have produced against the Astros are Houston area-native David Murphy (.333, five homers, 15 RBIs), Nelson Cruz (.318, eight homers, 23 RBIs) and Elvis Andrus (.326).
Astros: Humber back in relief
• With Keuchel and Erik Bedard joining the rotation, right-hander Philip Humber was informed on Wednesday by manager Bo Porter that he was being moved to the bullpen. Humber is 0-7 with an 8.82 ERA in seven starts, including a 16.20 ERA over his past four.
In his career, Humber has made 36 of his 87 appearances as a reliever, posting a 5.46 ERA. He gave up 13 runs in 14 innings over 10 relief appearances for the White Sox last year, but on Thursday, he struck out three in 1 1/3 scoreless innings.
"For me, it's a matter of getting right and getting more opportunities to get in there," he said. "I need to get better. That's the main thing, that's what I'm focused on, wherever I'm at -- rotation or bullpen. I've got to pitch better and I'm not satisfied with what I've done so far, so I'll keep working at it."
• Outfielder Jimmy Paredes went 3-for-8 with two doubles and two RBIs in his first two games after being recalled from Triple-A Oklahoma City, where he was hitting .366. Paredes, who batted .189 in 24 big league games last year, was 0-for-4 with three strikeouts on Thursday.
Worth noting
• Bud Norris' eight-inning outing on Wednesday was the first this season by an Astros starter to last longer than seven frames. Norris has three of the team's five starts that have gone at least seven innings.
• The Rangers stopped a two-game skid on Wednesday and still have not lost three games in a row this season.
Andrew Simon is a reporter for MLB.com. This story was not subject to the approval of Major League Baseball or its clubs.