Int'l Tax News

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Debt-Equity Rules Face Attacks, Possible Legal Challenges

by Alison Bennett
Controversial earnings-stripping rules faced sharp attacks on grounds ranging from legal authority to business harm at a packed IRS hearingwhere most of the 18 speakers had one overarching message on the regulations: Yank them.
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Deloitte Finds Concern About Scrutiny of Tax Structures

by Alex M. Parker
An accounting firm's survey of in-house tax and finance officers indicates taxpayers are increasingly concerned about heightened media and government scrutiny of tax structuresÔøΩbut not everyone is respondingwith new resources for their tax departments yet.
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Biz groups press IRS to withdraw proposed offshore tax rules

by Naomi Jagoda
Business groups and other stakeholders at a public hearing Thursday urged the Obama administration towithdraw, or at least narrow the scope of, proposed regulations aimed at curbing offshore tax deals.
"In this case, the damage dwarfs the benefits," PwC's Pam Olson said at a hearing at the Internal Revenue Service headquarters.
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UK asks Canada for advice on trade model post-Brexit

UK Brexit Minister David Davis has said he favours the Canadian economic trade modelwith Europe but could that cause trouble for Britain's lucrative financial services industry and manufacturers?

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EU VAT Action Plan: Heavier burden for businesses

  • By ITR
by International Tax Review
The European Commission's proposed VAT Action Plan is an ambitious attempt to reform the flailing regime. Joe Stanley-Smith picks through the details to look at the impact it could have on companies.
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Congressional Inaction Forced Treasury's Hand on Section 385

byAaron E. Lorenzo
Congress gave the Treasury Department no choice but to take a broad swing at companies' earnings-stripping practices, a top department official said.
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Notable state income tax implications of international operations

  • By PwC
by PwC
There are several aspects of state taxation that are particularly important to US and non-US companieswith international operations, including (1) nexus, (2) filing methodology, (3) tax return starting point, (4) treatment of foreign source income, (5) income apportionment, and (6) powers to adjust income. To complicate matters, there are no uniform rules among the states.
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Tax Reform Blueprint Sets the Stage for 2017

by Davidwilliams (Morning Consult)
While the public comment period for the Section 385 regulations has already closed, it's not too late for the Administration to reconsider such drastic action especiallywhen another alternative is available. That alternative is comprehensive tax reform. Specifically, the recently released GOP tax reform blueprint.
The plan, titled "A Betterway for Tax Reform,"was unveiled by House Speaker Paul Ryan (R-Wis.) and Houseways and Means Committee Chairman Kevin Brady (R-Texas) at the end of June.
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Beware of a Tax Reform Revolution

by Philip G. Cohen (CFO)
Tax reform proposals made by politicians should be scrutinized carefully and implemented gradually.
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Little Dialogue, Lots of Venting at Debt-Equity Reg Hearing

by Amy Elliott (Tax Notes)
By the end of the three-hour-long July 14 hearing on the debt or equity regs, many of the nearly 200 individualswho filled the IRS auditorium to capacity had clearly got the message following repeated calls for fullwithdrawal or -- failing that -- broad exemptions and generous transition rules as the government panelists largely remained silent.
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Global Corporation Tax Levels In Perspective

by Niall McCarthy
Corporate tax is levied on the income or capital of corporations or analogous entitieswith rates varying hugely between countries. Many countries impose it at the national level, though similar taxes are also imposed at state or local level. Based on theweighted average of state rates, the United States has a corporate tax level of 35 percent, considerably higher than most other developed nations around the globe.
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Leprechaun Economics Earn Ireland Ridicule, $443M Tax Bill

by Mark Deen & Dara Doyle
What price does a developed economy pay for posting 26.3 percent growth in a single year? Global ridicule, a renewed focus on its tax system and about 400 million euros ($443 million) a year.
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Spain to Raise 6 Billion Euros Through Corporate Tax Change

by Brett Allan King
Spainwill accelerate the rate atwhich companies must make advance payments of corporate income tax in 2017 and raise 6 billion euros ($6.6 billion) toward meeting European Union public deficit requirements, Acting Economy Minister Luis de Guindos said.
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OECD sets criteria for labeling countries asnon-cooperative tax jurisdictions, previews coming tax guidance

by Julie Martin
At the G20's behest, the OECD has identified objective criteria for determining if a country is "non-cooperative" tax jurisdictionwith respect to tax transparency, Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration, said during a July 12 OECDwebinar. OECD officials also discussed plans to release further tax and transfer pricing guidance.
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Brexit: Implications for indirect taxation and cross-border trade

The UK's VAT rules could change after an EU exit, meaning charges for imports and exports between the UK and EU member states. Preferential customs and duty rates in the single market could also end upon leaving the EU Customs Union.

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Australian federal election: What it means for tax

Malcolm Turnbull haswon the Australian federal election to remain as Prime Minister, but the lack of a strong majority is likely to giveway to political uncertainty around planned corporate tax measures.

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Brexit: Withholding taxes ahead for businesses

Multinational enterprises are consideringwhether to move their UK headquarters to one of the remaining 27 EU nations, aswithholding taxes could be charged once EU laws cease to apply.

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Singapore proposes laws to enact CRS and CbCR

The Inland Revenue Authority of Singapore (IRAS) is consulting on draft laws to introduce a number of corporate taxation changes announced in the 2016 Budget.

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STOP SAYING 'DOUBLE NON-TAXATION'

by Molly Moses
It's time to stop saying "double non-taxation." Yes, I knowwhat you're trying to invoke, but there's noway to keep it from sounding sillyÔøΩorworse, like something out of 1984.
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Treasury Releases Four Letters on Earnings-Stripping Rules

  • By FOIA

The Treasury Department released four letters on controversial earnings-stripping rules under provisions of the Freedom of Information Act, for theweek ending July 10.

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Ireland, Home to U.S. Inversions, Sees Huge Growth in G.D.P.

by David Jolly (The New York Times)
In the United States, politicians, lawmakers and officials have derided ''inversion deals,''which allow an American company to move its headquarters overseas to cut its tax bills. In Ireland, they are celebrating them.
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KPMG: Canada Still Has Edge in Tax Competitiveness

by Alex M. Parker
Canada has maintained its edge in tax competitiveness, according to a biennial survey from KPMG LLP.
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OECD to Propose Issuing Noncooperative Jurisdiction List in 2017

by Stephanie Soong Johnson (Tax Notes)
The OECDwill advise G-20 finance ministers at their upcoming meeting to adopt criteria to identify jurisdictions that fail to complywith international tax transparency standards, but to delay publishing the list until 2017 to allow jurisdictions to take corrective measures.
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Ireland Economy Grows as U.S. Companies Chase Lower Taxes

by Dara Doyle
Ireland's economy expanded by more than a quarter last year as companies moved their tax address to the island nation.
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OECD Will Review Relevant' Countries' Tax Policy Compliance

by Rick Mitchell
The OECDwill review some economically "relevant" non-member countries for compliancewith minimum standards under the international project against corporate tax avoidanceÔøΩeven if those countries decline to participate.
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EU Council Formally Adopts Antiavoidance Directive

  • By J.P. Finet
by J.P. Finet
The EU Council has adopted the anti-tax-avoidance directive 2016wTD 134-12: EU Council Directives as amended by the council in June.
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Musings on Portfolio Interest Exemption & Economic Substance

by Oscar Grisales-Racini (Tax Notes)
In this article, Grisales-Racini explores the interactions of three concepts: traditional planning and the so-called portfolio interest exemption; the economic substance doctrine in light of its recent codification; and the new global order predicated on substance in cross-border transactions.
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Low Hopes, Heightened Rhetoric on Eve of Debt-Equity Reg Hearing

by Amy S. Elliott (Tax Notes)
The government received about 200 unique comments in response to the proposed debt or equity regulations and 18 requests to speak at the July 14 public hearing, but the continued resolve of Treasury officials to proceedwith the goal of finalizing the regs has led to a rare joining of forces in the tax bar.
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Cash Pooling Exception Likely in Final Debt-Equity Rules: PwC

Bloomberg

by Alison Bennett
The Treasury Department is likely to include some form of exception for cash poolingwhen it finalizes controversial earnings-stripping rules, a PricewaterhouseCoopers LLP tax practitioner said.
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UK plans to cut 20% corporate tax rate

The UK plans to cut the corporation tax rate to the lowest of any major economy to attract businesses and investment post-Brexit, sparking concerns in the European Union that this could give the UK tax-haven status and trigger a 'race to the bottom'.

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EU Parliament votes on fairer taxation measures

The EU is a step closer to introducing an EU-widewithholding tax on company profits leaving the bloc, aswell as several new compliance and tax rules.

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US corporate tax cuts possible under Republicans' tax reform proposals

In a development that could reshape the US tax system, the House Republicans released a long-awaited tax reform blueprint to simplify the country's federal tax structure.

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Consolidating Acquired IP -- A U.S. Inbound Perspective

by Michael Steinsaltz
In this report, Steinsaltz surveys the landscape of partnership and corporate structures available for U.S. inbound companies thatwant to consolidate acquired intellectual property, noting recent tax law changes and options for the future.
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OECD Issues Follow-Up Draft on Limiting Interest Deductibility

Bloomberg

by Alex M. Parker
An OECD discussion draft outlined more details about the formula the organization recommends to cap interest deductibility as part of its effort to combat international tax avoidance.
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EU to Adopt Anti-Tax Avoidance Plan Despite Concerns

European Union finance ministers are set to formally adopt landmark legislation July 12 designed to clamp down on corporate tax evasion by rubber-stamping the Anti-Tax Avoidance Directive (ATAD) that includes measures to limit company interest deductions and impose exit taxation rules.
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Human rights law and the obligation of countries to cooperate on tax matters

by Aldo Caliari
When discussing tax policy a common tendency used to be to treat it as an exclusively domestic policy matter, one towhich only the prerogatives and obligations of the Statewhere the respective taxes are to be collected are relevant. Reality could be nothing further from the truth, as demonstrated by the amounts of revenue that get lost to tax evasion and avoidance by international actors because of their ability to straddle across a diversity of national jurisdictions.
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Rep. DeFazio to Propose Financial Transactions Tax

Bloomberg

by Laura Davison
Rep. Peter DeFazio (D-Ore.) is scheduled to introduce a plan to levy a 0.03 percent tax on most financial trades as he seeks to curb high-frequency trading.
The legislation, set to be introduced July 13, "will discourage risky trading behaviors that put everyday Americans' investments on the line and is expected to collect over $417 billion in revenue in the next decade," according to a July 11 statement from DeFazio's office.
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Treaty Overrides Where the Code's Legislative History Is Silent

Bloomberg

by Thomas S. Bissell
CPA Thomas Bissell considers tax code Section 7852(d)(1) and its effectwhere new revenue laws conflictwith pre-existing tax treaties. Bissell looks at how statements of legislative intent controlÔøΩincluding some made "retroactively"ÔøΩand questions raisedwhen none is apparent.
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OECD announces further developments in BEPS implementation

  • By OECD

Today the OECD has released (i) a discussion draftwhich dealswith the design and operation of the group ratio rule under Action 4 of the BEPS Action Plan, and (ii) standardised IT-format for the exchange of tax rulings (ETR) between jurisdictions – the ETR XML Schema – under BEPS Action 5. The OECD alsowelcomes Angola and the Seychelles as the 83rd and 84th members of the Inclusive Framework on BEPS.

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News Analysis: Will Brexit Unleash a Tax Haven?

by Ajay Gupta
A United Kingdom outside the European Union couldwell seek to counter any resulting loss in London's cachet as the center of international commerce by racing to the bottom on corporate taxes -- slashing the rate and exploiting the newlywon independence from Brussels to offer special one-off arrangements.
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Proposed Debt-Equity Regulations: What Problem Are We Solving?

by Peter B. Marrs
In this report, Marrs explains how the per se stock rule in the proposed section 385 regulationswould broadly apply to many ordinary course transactions, and he recommendsways for Treasury to narrow the scope of the regulationswhile more effectively addressing its concerns about U.S. earnings stripping and untaxed foreign repatriations.
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Presumptive British PM Slams Corporate Tax Dodging

by Stephanie Soong Johnston
U.K. Home Secretary Theresa May,who is poised to take over as prime minister on July 13, came out swinging against tax avoidance by large multinational corporations, vowing to crack down on the practice under her leadership.
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OECD Releases Draft on Groupwide Ratio Rule for Interest Expense

by Ryan Finley
The OECD's new discussion draft on the design and implementation of a groupwide ratio rule provides options for how to fill in the gaps left by the base erosion and profit-shifting report on action 4.
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U.S. Treasury Chief Lew Set for Apple Tax Showdown With EU

by Stephanie Bodoni & Aoifewhite
U.S. Treasury Secretary Jacob J. Lew is set to meetwith European Union antitrust chief Margrethe Vestager thisweek as she prepares to deliver a final verdict on a probe into Apple Inc.'s tax affairs in Ireland.
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May Pledges Corporate Crackdown as Osborne Courts Wall Street

by Alex Morales & Simon Kennedy
U.K. Home Secretary Theresa May pledged to crack down on corporate irresponsibility if she succeeds David Cameron as prime minister, as Chancellor of the Exchequer George Osborne headed towall Street on Monday to shore up investor confidence.
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Financial Giants Lobby Treasury to Ease Debt-Equity Rules

Bloomberg

by Alison Bennett
Some of the nation's biggest financial services companiesÔøΩincluding Citigroup Inc., Bank of America Corp. and JPMorgan Chase & Co.ÔøΩare all urging the Treasury Department to give them a break under controversial earnings-stripping rules.
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Cyprus revises tax treaty with India, ratifies new tax treaties, announces 2016 NID yields, and expedites ruline process

  • By PwC
by PwC
The Cyprus government has reported several important tax developments thatwill affect multinational enterprises doing business in Cyprus.
Regarding tax treaties:
  • The Cyprus government on June 30, 2016, announced that it completed negotiations and reached an agreement inwriting for a revised tax treaty between Cyprus and India.
  • The first tax treaty between Cyprus and Bahrain, signed on March 9, 2015, entered into force on April 26, 2016, andwill take effect on January 1, 2017.
  • The first tax treaty between Cyprus and Latvia, signed on May 24, 2016,was ratified by Cyprus on June 3, 2016. The treatywill take effect on January 1 of the year after the countries complete the legal formalities to bring the treaty into force.
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Speaker Paul Ryan And Chairman Kevin Brady Produce A Tax Blueprint To Make America Great Again

by Ralph Benko
Late last month, barely reported by the media amid all the general political static, something really amazing happened. Houseways and Means Chairman Kevin Brady released a truly great tax reform plan.
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Paris urges London to stay tax 'friendly' post Brexit

  • By Times Live
by Times Live
Amid fears of a fiscal "race to the bottom" French Finance Minister Michel Sapin on Monday slammed British plans to reduce corporation tax as part of plans to keep attracting foreign investment after last month's Brexit vote.
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Businesses warn that proposed Treasury tax rule goes too far

by Joseph Lawler
In a desperate attempt to stop companies from moving their headquarters out of the U.S. to avoid taxes, the Obama administration is advancing a rule that businesseswarn could have far-reaching consequences for many kinds of firms.
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