Int'l Tax News

Carbon emissions pricing is necessary to avoid some of the most catastrophic potential effects of globalwarming in a cost-effectiveway, but higher taxes likelywon't be enough on their own, a new report says.

A U.K. company acquired by GDF Suezwas taxable on gains from transferring claims on the insolvent Enron group to a Jersey subsidiary based on their market value, not their accounting value of zero.

Spain's finance minister recently told parliament that the governmentwill propose a digital services tax (DST) thatwould apply to online advertising services, brokering services, and the sale of user data collected over the internet.

Facebook UK Ltd. has defended its tax position after the company's 2017 results prompted critics to urge Chancellor of the Exchequer Philip Hammond to introduce a digital services tax, despite tax professionals' misgivings.

Ireland announced controlled foreign corporation rules and an exit tax regime targeting untaxed gains by companies that migrate or transfer assets out of Ireland, a change that took immediate effect, to the surprise of some.

Treasury hopes to release the bulk of the proposed regs relating to the international provisions of the Tax Cuts and Jobs Act in 2018, and to finalize most of those regs by June 2019.

The U.S. Treasury intends to build out the architecture of international tax provisionswith proposed regulations by the end of the year and to resolve gaps and complexities in the final rules by June 2019.

Taxpayers that are required to file transfer agreements to prevent the acceleration of transition tax payments under the installment planwill not be held to the October 9 filing date.

Malaysian Finance Minister Lim Guan Eng said Tuesday the government plans to introduce new tax measures to help raise funds to pay off national debt that has snowballed due to corruption under the previous government.

Multinational companies doing dealswith Canadian subsidiaries or affiliates often look to secure advance dealswith Canada that take several years and thousands or even millions of dollars to avoid the government's intense tax audit environment.

Israeli practitioners are divided onwhether new tax regulationswill counter the dampening effect of U.S. tax reforms on American investment in Israeli high-tech startups. The Tax Authority rules provide a simpler "Green Route" for companies to restructure as the Israeli subsidiary of a foreign parentwithout triggering a tax eventÔøΩeasing businesses' development and capital-raising.

Australia is trying to shut down a gap in its tax law that allowed partnerships to fall outside of anti-avoidance rules. The loophole meant that partnerships thatwere 99 percent-owned offshore and only one percent Australian, could potentially avoid the country's multinational anti-avoidance law.

Switzerland has for the first time exchanged information on about 2 million financial accountswith foreign authorities, according to its Federal Tax Administration.

The Netherlands' coalition governmentwill "reconsider" a controversial tax break designed to attract foreign businesses to the country after Unilever scrapped a planned move from London to Rotterdam.

Austria, the European Union's presidency holder,will address fears that the proposed tax on digital companies could lead to double taxation.

Countries can no longer claim U.S.-based tech companies like Facebook Inc. don't pay enough in tax, the OECD's top tax official Pascal Saint-Amans said Oct. 5 in remarks that are a major marker in a global debate over levies on multinational companies.

Large and multinational companieswill get a boost under New Zealand's new research and development tax plan. The new tax incentive, announced Oct. 3 and set to operate from 2020, gives the large and global firms access to an incentive scheme fromwhich they've previously been excluded.

Ongoing budget negotiations between Spain's minority Socialist government and the leftist Unidos Podemos alliance could bring a higher top income tax rate and more tax agency scrutiny for popular investment schemes.

Officials from theworld's largest economies are calling on the OECD to consider changing theway multinational companies are taxedworldwideÔøΩinspired in part by U.S. tax reform saidLafayette G. "Chip" Harter, deputy assistant secretary of international tax affairs at the Treasury Department's Office of Tax Policy.

The government took the biotechnology and pharmaceutical industries' unique financing into account in its decision to consider relaxing rules for spinoff transactions. The Internal Revenue Service announced Sept. 25 that itwas reassessing requirements that units to be spun off of a corporation generate revenue prior to the transaction.

The U.S.will speak up for its foreign-derived intangibles income regime at the recent OECD forum. This article provides updates on spinoffs; applying the 2017 tax law's provisions to corporations at the consolidated group level; and the push for uniform state approaches to partnership audits.

Airbnb's tax arrangements have come under scrutiny from UK authorities, intensifying pressure on the home-sharing app that has transformed the market for short-term holiday rentals since its launch in 2008.

The Czech Republic joined opposition by Ireland, Finland and Sweden to the European Union's proposed tax on big Internet companies in a joint paperwarning that the measures may breach international treaty obligations.

Chinawill increase export tax rebates from Nov. 1 and quicken export tax rebate payments to support foreign trade, the cabinet said on Monday, as a tradewarwith the United States escalates.

Canada is lagging behind its peerswhen it comes to reviewing and reforming its tax system, and there's a real risk that the country's tax competitiveness is on the decline, an accountancy group has said.

The outgoing inspector general of the Australian Taxation Office (ATO) has recommended that an oversight authority be created to supervise the agency, similar to management boards in Canada, the United Kingdom, and the United States.

India's new framework for determining significant economic presence (SEP) is having little impact because key questions regarding the thresholds for establishing a presence have yet to be answered, a practitioner said.

Support is growing for beneficial ownership transparency (BOT) in the United States,which has become inundatedwith "authoritarian capital" from other countries, according to an independent agency of the U.S. government.

Congress may have intended to require a causal relationship between the hybrid nature of a transaction and the application of a preferential regime in order to deny a deduction, according to an IRS official.

Despite predictions that the OECD's base erosion and profit-shifting projectwill cause a surge in international tax controversy, giving tax authorities the same information from the beginning may actually help multinationals avoid disputes.

Karen Sowell of the New York State Bar Association Tax Section has submitted a report on proposed transition tax regulations (REG-104226-18) under section 965, addressing the double counting rule, refunds for taxpayers making the section 965(h) election, clarification of the domestic passthrough entity, and many other aspects of the regs.

The IRS is standing by its refund policy for overpayment of the transition tax in the face of strong practitioner criticism, though the agency admits that the issue is not yet closed.

The IRS is nearly finished drafting proposed regulations setting the groundwork for implementing the Tax Cuts and Jobs Act's international provisions,which have gained international recognition as a possible model for consensus anti-profit-shifting measures.

Dutch Prime Minister Mark Rutte said his governmentwould reconsider plans to scrap its dividend tax in a major political climbdown only hours after Unilever dropped plans to move its headquarters to the Netherlands. Rutte,who had argued that getting rid of the 15 percentwithholding tax on dividendswas vital for the country's business climate, said his government must reconsider its entire package of tax reforms.

The Tax Cuts and Jobs Act's reduction in corporate income tax rates has revived the popularity of C corporation entity structures, but practitionerswarned Thursday there is no one-size-fits-all choice for every business.

Failing to participate in the global digital tax debatewould be a mistake the USwould regret, say a senior tax executive and former Microsoft tax counsel.

A bloc of Eastern European states said Friday that theywere supporting the European Union's temporary digital tax. The statement of finance ministers from the so-called Visegrad Group signals a core of support for the controversial tax,which has divided European Union member states since the continent's executive arm, the European Commission, proposed the idea in March.

Tax administrations need to harmonise their tax filing and data requirements to give taxpayers a better chance of complying, say in-house practitioners and tech aficionados.

A financial services firm's French branch shouldn't be allowed to deduct VAT for transactions undertaken for its London headquarters thatwouldn't be deductible in both the United Kingdom and France, an advocate general has recommended.

An OECD-U.N. program created to strengthen tax auditing capacity in developing countries has reported yet another year of good progress, helping tax administrations claw back more than $400 million in additional tax revenues to date.

Despite Trump's import taxes, US trade gap rises for third straight month to $53.2 billion in August.

Nearly 100 non-EU countrieswould have to require multinational companies to report their taxes and profits on a country-by-country basis under proposed criteria for the bloc's tax haven blacklist.

Japanese automakers doubt the viability of U.S-Japan bilateral advance pricing agreements saying the IRS has become increasingly aggressive in its audits, and rather seek legal relief through U.S. courts. APA negotiations between the U.S and Japan are set to take place in mid-October.

Multinational corporations scrambling to meet IRS filing deadlines have more time to make basis adjustments under the new transition tax.

Law professors are on the IRS's side in a federal court case involving Intel subsidiary Altera Corp., as the agency and company prepare for a second round of arguments in the highlywatched tax case. Legal professors from around the country urged the U.S. Court of Appeals for the Ninth Circuit to keep its original ruling and accept the IRS's 2003 regulation that requires domestic companies to sharewith their foreign units the cost of stock compensation granted to employees.

Britainwill unilaterally implement a digital service tax if there is nowider international agreement soon on how to tax theworld's biggest internet companies, finance minister Philip Hammond said on Monday.

The new concepts of virtual, or digital, permanent establishment and its tax treatment are creating a challenge on a global scale. Part 1 in this series looks at the latest initiatives being taken at domestic and OECD levels.

Australiawants feedback on plans to tax large digital businesses, as part of government efforts to ensure online companies are taxed as fairly as businesses based in the country.