Int'l Tax News

The Treasury Department and the IRS proposed regulations aimed at reining in “Killer B” triangular reorganizations involving foreign corporations, which the government says companies have used in the past to avoid taxes.

Irish corporate tax receipts have dropped two months in a row, with third-quarter revenues falling €700 million short of projections as researchers predict a slowing corporate tax take in line with modest economic growth.

The OECD announced Tuesday that countries involved in the global tax deal negotiations have agreed on a multilateral convention to implement a rule aimed at helping developing countries collect more tax under treaties that set low withholding rates.

Germany and China have pledged to help developing nations administer the global minimum tax rules just months before they’re poised to go into effect.

A top Dutch tax official said the Netherlands is preparing for the global minimum tax rollout and will support developing countries in international tax policymaking at the United Nations following talks with US tax officials.

Singapore aims to roll out a safe harbor as part of its adoption of the global minimum tax rules, according to a top government official.

Singapore will strive to implement a qualified domestic minimum top-up tax safe harbor to make tax compliance as easy as possible for companies affected by pillar 2 rules, according to a top government finance official.

The United States-Taiwan Expedited Double-Tax Relief Act, which is advancing to the full Senate, would provide an array of tax benefits on certain income earned by qualified residents of Taiwan from US investments or activities.

The International Accounting Standards Board changed small company accounting rules Friday in order to simplify issues created by OECD global minimum tax rules.

The United Kingdom has published more draft measures revising its pillar 2 legislation to reflect safe harbors and other features of the OECD’s latest administrative guidance for the global anti-base-erosion rules.

The French government is moving to adopt the EU’s pillar 2 directive, implementing global anti-base-erosion rules and a domestic minimum top-up tax, according to its 2024 draft finance bill.

Hungary’s finance minister has started talks with large Hungarian companies about ensuring the country remains competitive as it prepares draft legislation in the fall for transposing the EU’s global minimum tax directive into domestic law.

The Italian government modified a controversial windfall tax on banks, giving lenders an option to avoid paying if they set aside additional capital reserves.

The Office of the U.S. Trade Representative has again pushed back against Canada’s plans to introduce a digital services tax, days after American lawmakers warned that the tax, if imposed, might damage Canada-U.S. trade relations.

Government officials from Norway and Denmark announced that their countries are joining the Canadian-led global carbon pricing challenge and emphasized the importance of international cooperation on carbon taxes to effectively reduce emissions.

The Biden administration on September 22 issued final rules that would prohibit chip companies vying for a new infusion of federal cash from carrying out certain business expansions, partnerships and research in China, in what it described as an effort to protect United States national security.

A senior Treasury official has cautioned against efforts by the U.N. to pursue a separate multinational tax agreement, arguing that it would fundamentally undermine the progress made by the OECD’s inclusive framework.

The IRS is considering extending the period in which taxpayers can rely on old foreign tax credit rules, while the agency mulls changes to newer rules.

Several world leaders at a United Nations high-level panel said that the OECD is not the preferred organization to lead the international tax cooperation agenda, but existing work should not be duplicated.

EU Tax Commissioner Paolo Gentiloni told members of the European Parliament that the EU will have to work hard to avoid a situation in which private actors or jurisdictions find loopholes in pillar 2 of the OECD's global tax plan.

House Republican taxwriters are hoping other countries will delay implementation of pillar 2 of the OECD global tax deal while they separately encourage leaders to implement versions of the United States’ global intangible low-taxed income regime.

A bipartisan group of House Ways and Means Committee members called on the Treasury, the US Trade Representative, and the Organization for Economic Cooperation and Development to push back on Canada’s decision to impose a digital services tax.

The Dutch tax plan presented to Parliament on Tuesday highlighted ways to make up for uncertain tax revenues from the global minimum tax to start in 2024.

Although some EU member states have started transposing the EU’s global minimum tax directive into their domestic law, others aren’t acting as quickly, and time is running out, according to a European Commission official.

Stephen A. Bonovich considers the inexplicable and unexplained decision to design pillar 2 to attack various forms of tax rate competition but ignore state subsidies, even though tax academicians, officials, and practitioners have long concluded that such a design is highly irrational and gives rise to market distortions — the exact opposite of what pillar 2 seeks to achieve. He also looks at the practical implications of ignoring those views for the United States, the EU, and China.

Introduction of the 15% global minimum tax will lead jurisdictions to seek new ways of offering tax breaks to attract companies, according to a report on launch of the tax in the European Union.

Martin A. Sullivan uses data from Form 10-K reports to illustrate some policy shortcomings of recent tax reform efforts, focusing on intellectual property transfers and Switzerland’s status as a tax haven.

Ireland is considering a plan to offer corporate tax breaks for dividend income and foreign branches.

Bruce Zagaris breaks down the effect changes in global tax trends have had on Caribbean nations and examines measures to encourage growth in the region.

The Senate Finance Committee on September 14 passed a bill that would deepen economic ties between the United States and Taiwan and effectively create a tax treaty that is expected to pave the way for more Taiwanese investment in the American semiconductor industry.

Ryan Finley asserts that the apparent failure of the United States’ global crusade against digital services taxes should prompt a reassessment of U.S. policy.

Nana Ama Sarfo outlines some open questions generated by the U.N. secretary-general's recent report on international tax cooperation.

The US reiterated its preference Tuesday for what it says is an easier method for determining which transactions will be affected by new streamlined global transfer pricing rules.

Countries should work quickly on pillar 1 of the OECD’s two-pillar tax reform plan, including unblocking progress on the amount A multilateral convention and completing amount B transfer pricing simplification rules, G-20 leaders said.

Canada's digital services tax legislation could weaken the two-pillar plan to modernize corporate tax rules from the OECD/G-20 inclusive framework on base erosion and profit shifting, according to a U.S. trade group.

The Group of 20 leaders are calling for a resolution on remaining issues in the global tax deal, including tackling transfer pricing and crypto issues.

The Canadian government should withdraw its plans for a digital services tax to avoid creating “perverse incentives” for countries to undermine a major OECD global tax reform agreement, tech companies said.

The European Commission says it used “valuable insights gained from many years of negotiations” on corporate tax proposals — including those that failed — to design its much-awaited proposal for a common corporate tax framework.

Sol Picciotto explores the origins of the global anti-base-erosion tax, the main element of pillar 2, its current implementation, and the role the United States could play in supporting or opposing these international tax reforms.

In a tax report delivered to the G20 Friday, the Organization for Economic Cooperation and Development said that the 15% global minimum tax is expected to rake in $200 billion annually, and that by 2025 more than 90% of multinational corporations making over 750 million euros ($803 million) will be subject to it.

Nine House Republicans pressed the German Minister of Finance to repeal Germany’s century old tax on intellectual property income that’s recently troubled US companies.

African countries are partnering with three donors to develop a digital tax system for the continent’s governments to own following years of costly, piecemeal updates to their tax administration tools.

The new corporate minimum tax has become a challenge for the Biden administration, which has faced intense lobbying from industries that could be on the hook for billions of dollars in new taxes. Those groups have been flooding the Treasury Department with letters asking for lenient interpretations of the law and trying to create new loopholes before their tax bills come due next year.

A proposed EU common corporate tax system would apply to the same large multinational and domestic groups in scope of pillar 2 and harmonize transfer pricing rules across the bloc.

The Irish government has increased the effective tax rate of its knowledge development box, responding to the treaty-based subject-to-tax rule under pillar 2 of the OECD-brokered tax reform plan.

Tax practitioners are getting increasingly anxious about a major foreign income tax case before the Supreme Court that they fear could tear down wide swaths of the tax code, as a deadline approaches for parties to weigh in. 

Congressional tax-writers start their trek back to Washington this week with plans to consider a Taiwan tax bill, scrutinize the global tax deal, and hash out funding for the IRS.

Ryan Finley explains why pillar 2 adoption should prompt a reassessment of patent boxes and other income-based tax incentives for intellectual property.

Martin A. Sullivan considers whether the foreign-derived intangible income provisions of the Tax Cuts and Jobs Act did, in fact, raise revenue for the U.S. fisc.

The OECD/G-20 inclusive framework on base erosion and profit shifting should expand the scope of amount B of pillar 1 to include digital services, according to the Information Technology Industry Council.