Int'l Tax News

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Republicans Pressure Treasury on Debt-Equity Regulations

Bloomberg

by Kaustuv Basu
Houseways and Means Republicans are adding to criticism of the Treasury Department's controversial debt-equity regulations, calling the retroactive April 4 effective date for the regulations "inappropriate."
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Subpart F Loopholes' Described in the President's FY 2017 Budget

Bloomberg

Lowell Yoder of McDermottwill & Emery looks at current law Subpart F "loopholes" described in the president's 2017 budget. "Subpart F planning techniques involving the 30-day rule, toll manufacturing arrangements and digital income are currently available," the authorwrites.
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Profit-Shifting Structures: Making Ethical Judgments Objectively

This is a two-part report; Part 2will appear in the July 4 issue of Tax Notes. In this first part of the report, Kadet and Koontz set out an ethical benchmark that multinational corporations can use to objectively test the propriety of their profit-shifting structures. This benchmark focuses more on business operations and less on tax rules.
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The True Economic Effects of Corporate Inversions

by Doron Narotzki (Tax Notes)
In this report, Narotzki argues that corporate inversions are not as harmful as they are portrayed to be and that government efforts may be better spent by allowing inversions or reforming the tax code to encourage businesses to remain domiciled in the United States.
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Tax challenges, disruption and the digital economy

by Pascal Saint-Amans (OEDC Observer)

The digital economy is a transformative process, brought about by advances in information and communications technology (ICT)which has made technology cheaper and more powerful, changing business processes and bolstering innovation across all sectors of the economy, including traditional industries. Today, sectors as diverse as retail, media, manufacturing and agriculture are being impacted in someway by the rapid spread of digitalisation. In the broadcasting and media industry, for instance, the expanding role of data through user-generated content and social networking have enabled internet advertising to surpass television as the largest advertising medium.

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As U.S. Works to Curb Inversions, Talk of Pre-Inverting'

Bloomberg

by Alex M. Parker
As the Internal Revenue Service and Treasury Department seek moreways to keep U.S. companiesÔøΩand their intellectual propertyÔøΩfrom leaving these shores, lawyers and accountants are beginning to ask a question thatwould have seemed nonsensical a few decades ago:why don't companies incorporate outside the U.S. to beginwith?
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Offshore Earnings Tax Seen as Troubling Under GOP Plan

Bloomberg

byAlison Bennett
U.S. companieswould be far less likely to invert under the territorial tax system proposed by House Republicans, attorneys sayÔøΩbut a tax on more than $2 trillion in earnings currently held offshore is raising eyebrows.
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Surprise Brexit Vote Casts Uncertainty on U.K. and EU's Future

by Stephanie Soong Johnson (Tax Notes)
The unprecedented and unexpected vote in favor of the United Kingdom leaving the EU has sent political and financial shockwaves throughout theworld, leaving serious questions about the tax systems and economic futures of both Britain and Europe in itswake.
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Swiss IP Structures Attractive to U.S. Tax Directors (1)

by Kevin A. Bell
Switzerland, a sophisticated, mountainous nation of 8 million already attractive to U.S. tax directors seeking a European jurisdiction for their group intellectual property, is likely to maintain its competitive position in the post-BEPSworld.
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European Commission's CbCR Proposal Raises Serious Concerns

by Xaver Ditz
The OECD's BEPS project has increased the focus on country-by-country reporting, resulting in several countries adopting it in domestic legislation. Xaver Ditz of Flick Gocke Schaumburg explainswhy the European Commission's proposal for EU-wide disclosure of such information faces greater resistance.
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AICPA Submits International Tax Reform Comments To House Ways and Means Committee Chairman Brady

by Troy K. Lewis
Troy K. Lewis of the American Institute of CPAs in a June 23 letter to Houseways and Means Committee Chair Kevin Brady, R-Texas, made recommendations and sought technical clarifications on the international tax provisions of the Tax Reform Act of 2014, such as changes to the foreign tax credit system and FICA taxes for foreignworkers.
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U.S., Luxembourg in Treaty Talks to Close Tax Break

by Alison Bennett
Luxembourg's efforts to show theworld it is cooperating in shutting down double nontaxation are likely to continue, as the country faces increasing criticism in both Europe and the U.S.
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Canada Court OKs Mark-to-Market for Foreign Exchange Options

by Peter Menyasz
Income earned from foreign exchange option contracts may be calculated on a mark-to-market basis for income tax purposes, Canada's Federal Court of Appeal confirmed (Kruger Inc. v. the Queen, Canadian Fed. Ct. of App., No. A-296-15, 6/22/16).
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South Africa proposes carbon tax relief in draft law

by Amelia Schwanke
South Africa is pushing aheadwith a proposed carbon tax thatwill increase the tax burden for companies, but a carbon offset could offer somewelcome tax relief.
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EU Parliament to vote on ambitious call to rewrite EU tax system

International Tax Review
Companies operating in the EU may face an EU-widewithholding tax and a host of new compliance and tax regulations if the EU approves recommendations by the Special Committee on Tax Rulings.
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video: Exclusive interview with Pascal Saint-Amans

by Amelia Schwanke
Pascal Saint-Amans, director of the Centre for Tax Policy and Administration at the OECD, sat downwith International Tax Review reporter Amelia Schwanke to discuss the most prominent topics in tax because although "tax isn't fun, it's absolutely fundamental if youwant to have services to the population".
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Leading Democrats, Republicans Split on House GOP Proposed Tax Reform

by Evan Fallor
The House GOP blueprint for tax reform released Friday sparked mixed reactions in Congress,with leading Democrats criticizing its lack of detail and Republicans lauding its proposed pro-growth efforts through limits on deductions, exclusions and credits in the current tax code.
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Countries Gear Up For Key BEPS Meeting

by Mary Swire
The OECD's Committee on Fiscal Affairswill hold its first meeting under its new inclusive framework for non-OECD and non-G20 territories to discuss the next step on base erosion and profit shifting (BEPS).
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Tax policy after Brexit

by Richard Teather
The opinion pollswerewrong again; Brexit haswon. But now the hardwork begins of building alternative structures, and decidingwhat to dowith the UK's new freedom of independent action.
One aspect that didn't get a mention in the campaignwas the huge extent towhich the EU already influences the UK's tax agenda.
The next couple of yearswill determinewhether the post-Brexit UK becomes an outward-looking global economy or retreats into nationalistic tariffwars.
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India amends application date of General Anti-Avoidance Rule

by Amelia Schwanke
Investors in India have been given room to breathe as the Central Board of Direct Taxes (CBDT) amends the effective date of the General Anti-Avoidance Rule (GAAR).
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Brexit Seen Boosting EU Drive to Harmonize Corporate Tax

Bloomberg

by Joe Kirwin
The U.K.'s exit from the European Union is expected to strengthen the drive led by Germany and France to harmonize corporate tax policyÔøΩespeciallywhen it comes to an upcoming attempt to revitalize a plan to develop a single set of rules thatwould allow cross-border companies to file a single tax return for their EU activities, according to European Parliament members, tax practitioners and some academics.
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Germany publishes draft bill implimenting BEPS related measures

  • By PwC

PwC

by PWC
The German Federal Ministry of Finance on June 1, 2016, published a draft billwhich implements the EU directive mandating the automatic exchange of tax information in addition to measures targeting base erosion and profit shifting (BEPS). The bill's main legislative changes include the adoption of the Organization for Economic Co-operation and Development's (OECD's) recommendations for country-by-country reporting (CbCR) and the 'Master File/Local File' concept for transfer pricing (TP) documentation.
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US and Luxembourg announce retroactive change to triangular branch rules in treaty

  • By PwC

PwC

The US and Luxembourg on June 22, 2016, agreed to amend a protocol to the existing income tax treaty that addresses the potential for double non-taxation for US-source income of a Luxembourg company attributable to its US branch. parliamentary action, the timing ofwhich is uncertain, but could be as early as late June 2016.The amendment affects the 'triangular branch rule' for taxpayers using US branches taxed in neither the US nor Luxembourg.
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House Republicans outline plan for comprehensive tax reform

  • By PwC

PwC

House Republicans today released a 35-page report on tax reform that proposes to lower corporate and pass-through business tax rates, reduce individual tax rates, provide full expensing for business costs (with no deduction for net business interest expense), and move the United States from aworldwide international tax system to a 'territorial' dividend-exemption system.
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Is Corporate Integration a Good Idea?

  • By Avi-Yohah

In this installment of the Star Forum, expertsweigh in on the following question:

Senate Finance Committee Chair Orrin G. Hatch, R-Utah, has announced that he is drafting a proposal in favor of corporate integration. Do you think that corporate integration is a good idea?what factors should Hatch consider as he is drafting his proposal?
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Germany Agrees to Toughen Inheritance-Tax Rules

by Ruth Bender and Andrea Thomas (Wall Street Journal)
Germany's ruling coalition agreed to restrict tax exemptions on some corporate successions, allowing them only for smaller companies or those in difficulty, after months of debate overwhat critics have called lopsided policies that benefit mainly the country's richest families.
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10 Observations Concerning International Tax Policy

Daniel Shaviro, thewayne Perry Professor of Taxation at New York University Law School, presents a slightly revised version of a luncheon talk he gave at the National Tax Association's 46th annual spring symposium on May 12.

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Do U.S. Income Tax Treaties Override The Section 4985 Anti-Inversion Tax on NRA Insiders?

Bloomberg

by Thomas S. Bissell
CPA Thomas Bissell examines the possibility that U.S. income tax treaties may override application of the tax code Section 4985 excise on "insiders" of expatriating corporations for nonresident aliensworking mostly or entirely outside the U.S.
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IRS Makes Changes to Corporate Inversion Rules

  • By Bloomberg

Bloomberg

by Bloomberg
The IRS corrected guidance related to efforts to limit U.S. companies from changing their tax residence to cut or avoid U.S. taxes.
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U.S. Corporate Tax Is Driving Inbound Acquisitions, Panel Says

by Ryan Finely (Tax Notes)
The United States' high corporate income tax rate and extraterritorial system are major contributors to a recent surge in acquisitions of U.S. companies by foreign multinationals, according to a panel of economists.
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Speech by Commissioner Pierre Moscovici at the Tax Congress of the Berlin Tax Forum 2016

  • By Commissioner Pierre Moscovici
European Commission Commissioner Pierre Moscovici delivered a speech on Europe's latest initiatives on corporate tax policy at the Tax Congress of the Berlin Tax Forum 2016.
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Commission welcomes agreement on new rules to tackle tax avoidance

  • By European Commission

The Commission haswelcomed the agreement reached by Member States on their general approach for far-reaching new rules to eliminate the most common corporate tax avoidance practices.

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Switzerland: The Swiss tax function of tomorrow.

International Tax Review

by Andre Claes, David McNeil and Sarah Drye

The evolution of the global tax environment is forcing international tax functions to consider new and innovativeways of effective managemen

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The Case for Not Eliminating the Corporate Income Tax

by Scott Greenberg (Tax Foundation)
This past Friday, two prominent tax economists released a detailed and thoughtful tax reform proposal, calling for a major overhaul of the U.S. corporate income tax.
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OECD Backs US International Tax Reform Efforts

  • By Ulrika Lomas
by Ulrika Lomas (Tax News)
The Organisation for Economic Co-operation and Development has, in its recent economic survey of the United States,welcomed steps taken by the Government to reform the country's international tax system.
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EU agrees corporate tax avoidance rules

by Emma Rumney (Public Finance International)
New rules to combat corporate tax avoidance by multinational companies are to be adopted across the European Union after member states agreed a package of measures today.
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EU agrees on rules to tackle multinational tax avoidance

International Tax Review

by Anjana Haines
European finance ministers have finally agreed on plans to crack down on aggressive tax planning by multinationalswith the proposed Anti-Tax Avoidance Directive.
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EU struggles to close tax loopholes with new law

EU states have cleared a deal that aims to close some of the loopholes used by large companies to dodge taxes.
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Weighing The Corporate Tax Implications Of A 'Brexit'

Forbes

by Joe Harpaz
While there have been hundreds of articles chronicling the arguments for and against the Brexit and gauging the potential impacts to the British economy and to individual Britons, less has been done to examine the possible corporate tax implications of the move.
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Will BEPS Be a Game-Changer as OECDs Pascal Saint-Amans Claims?

It has been said on more than one occasion that, in the area of international taxation generally, the OECD/G20 Base Erosion and Profit Shifting (BEPS) projectwill be a game-changer. Pascal Saint-Amans, director of the OECD Center for Tax Policy and Administration, recently reiterated the claim in an interviewwith Axel Threlfall, Reuters editor-at-large, at the recent OECD Ministerial Council Meeting in Paris.
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Corporate taxation: MEPs call for tax haven black list, patent box rules, CCCTB and more

by Ron Korver (European Parliment)

Recommendations to make corporate taxation fairer and clearerwere voted by the Special Committee on Tax Rulings II on Tuesday evening. They call for an EU public register of beneficial owners of companies, a tax havens blacklist, sanctions against non-cooperative tax jurisdictions, action against abuse of "patent box" regimes, a code of conduct for banks and tax advisors, tax good governance rules in all EU trade agreements and awithholding tax on profits leaving the EU.

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Brexit: What would it really mean for tax?

International Tax Review

by Tim Sarson

Tim Sarson, a tax partner at KPMG in the UK, explainswhy tax professionals should probably ignore much of the noise around 'Brexit', at least for the time being. This clears the path for companies to focus on the changes that really matt

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here.

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Brexit: Britan, the EU and the most worried tax implications

International Tax Review

If the UK votes to leave the European Union (EU) on June 23 multinationals face an urgent problem: how to copewith uncertainty in the tax system.

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Cross-Border Tax Avoidance Likely IRS Audit Campaign Target

The IRS's new technique of selecting tax issues to scrutinize via "campaigns" is likely to have a sharp focus on cross-border tax evasion through transfer pricing and treaty manipulation.
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States Show Why Tax Havens Are Wonderful': Economist Laffer

Economic growth in stateswith no income tax exemplifieswhy being a "tax haven iswonderful," economist Arthur Laffer said.
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EU Anti-Tax Avoidance Deal Clears Legislative Hurdle

by Joe Kirwin
The European Commissionwill begin a monitoring exercise to determinewhether the U.S., Japan and China adopt OECD strategies to combat profit shifting, after the commission reached an agreement to crack down on corporate tax avoidance.
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Counterproductive Treasury Inversion Policy

by George Ill Nastas
George Nastas III explains how corporate inversions are a symptom of bad U.S. tax policy andwhat the government could do to make U.S. businesses more competitive.
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European Council Approves Compromise Anti-Tax-Avoidance Directive

Following the lapse of the deadline for member states to raise any final objections, the European Council has approved a laxer version of the anti-tax-avoidance directive proposed by the European Commission in January.
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TAXE II Recommends EU-Wide Ownership Register, Tax Haven Blacklist

by J.P. Finet
An EU-wide register of beneficial ownership, a tax haven blacklist, sanctions against noncooperative jurisdictions, and actions to stop the abuse of patent box regimes top the recommendations in the final report of the European Parliament's special committee on tax rulings.
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Rand Paul, Others Ask Treasury to Renegotiate Tax Treaties

byKevin A. Bell
Three Republican members of the Senate Foreign Relations Committee asked the Treasury Department to renegotiate the information exchange articles of pending U.S. tax treatieswith Chile, Hungary, Japan, Luxembourg, Poland, Spain and Switzerland.
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