Int'l Tax News

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BEPS Corner: Are the Final BEPS Reports on Actions 8-10 Effective Now?

by Jason Osborn, Brian Kittle and Kenneth Klein (Tax Notes)
In this article, the authors discuss the impact of the final BEPS actions 8-10 reports,which contain final, currently applicable revisions to the OECD transfer pricing guidelines.
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Digital Economy Requires International Cooperation on VAT, OECD Official Says

by Ryan Finley (Tax Notes)
Cross-border transactions involving digital products have made VAT enforcement a global issue that can be effectively addressed only through coordinated international efforts and a globally consistent set of rules, according to Stéphane Buydens, VAT policy adviser at the OECD.
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Apple's Income Should Be Taxed in U.S., Not Ireland, Lew Says

by Alexander Lewis (Tax Notes)
The European Commission's finding that Apple Inc. received illegal state aid from Ireland to the tune of ÔøΩ13 billion represents an attempt to tax income that belongs to the United States, according to Treasury Secretary Jacob Lew.
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Tax Move Is EU''s Latest on Tech -- WSJ

by Sam Schechner (Nasdaq)
The European Union's decision Tuesday that Apple Inc. owes roughly 13 billion euros ($14.5 billion) inwhat it calls uncollected taxes over a decade, represents a new high-water mark in the bloc's efforts to rein in alleged excesses of American tech giants.
But it is also just the first shot inwhat is expected to be a busy autumn for European officials,who are pushing forward a raft of regulations and investigations aimed at altering the behavior of a cadre of U.S.-based internet superpowers.
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Yesterday, Outraged by Apples Tax Dodge. Today, by Its Tax Bill

by Alan Rappeport (The New York Times)
American lawmakers have for years been assailing companies for dodging taxeswith overseas maneuvers. But now that the European Union has done something about it by trying towrest billions of dollars from Apple, those officials have offered a response viewed by many as rifewith hypocrisy: collective outrage.
Tax avoidance has become a lightning rod as the presidential campaign has taken on a strong populist cast, and leading Republicans and Democrats in Congress have demanded that companies be forced to pay their fair share.
Despite all that, Apple now has the federal government standing up for it after the European Union's executive commission ordered Ireland on Tuesday to collect $14.5 billion in taxes from the company.
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Intangibles Regs Grant Perpetual Life, but Are They 'Useful'?

by Kristina L. Novak, Mark Thomas and Cym H. Lowell (Tax Notes)
In this article, the authors argue that in granting perpetual useful life to intangibles, the recently proposed section 367(d) regulations appear to be inconsistentwith much of the data and experience provided by today's dynamic business environment. They conclude that Treasury's view is unfortunate for taxpayers in an area already fraughtwith litigation and that it may have unintended consequences for the IRS.
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Practitioners: EU Apple Case Will Cause Chaos, Hurt BEPS

Bloomberg

by Alex M. Parker
The European Commission's decision to require Apple Inc. to retroactively pay 13 billion euros ($14.5 billion) in unpaid taxes increases uncertainty and chaos in the international tax system, throws tax rulings and advance pricing agreements into question and undermines other global efforts to dealwith international tax avoidance, practitioners say.
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Lack of U.S. Tax Overhaul Is a Shame,' Saint-Amans Says

Bloomberg

by Rick Mitchell
The U.S. is seeing EU countries make a grab for tax revenue from U.S. companies because it has failed to implement key tax policy changes, the head of OECD tax policy said.
For the DTR story, gohere. (subscription required)

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Lew: EU's Apple Tax Ruling Shows U.S. Companies Targeted

Bloomberg

by Saleha Mohsin
Treasury Secretary Jacob J. Lew said the European Union is singling out American companies for tax investigations as shown by its ruling thisweek that Apple Inc. must pay Ireland more than 13 billion euros ($14.5 billion) in back taxes.
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EU Apple Ruling to Hurt Global Companies: Technology Group

Bloomberg

by Alison Bennett
Global technology companies face big problems overseas and in the U.S. after the European Union ruled that Apple Inc. owed $14.5 billion in taxes it avoided through Irish tax agreements, according to a major technology group that counts Apple among its 60 members.
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Corporate Foreign Tax Credit Claims Rise as Economy Recovers

Bloomberg

by Colleen Murphy
The number of corporations looking to reduce their income taxes increased 6.9 percent in 2012, the IRS said.
In total, 7,190 U.S. corporations claimed the creditÔøΩsignaling recovery from the "hangover" of the Great Recession, Robertonwilliams, the Sol Price Fellow at the Urban-Brookings Tax Policy Center, told Bloomberg BNA Aug. 31.
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Fighting Apple's Record Tax Bill: What Happens Next?

Bloomberg

by Stephanie Bodoni
Apple Inc. and Ireland have always vowed to go to court to fight a negative European Commission ruling over the iPhone maker's fiscal affairs.
Ireland received the commission's full decision Aug. 31, andwillwant to study exactlywhy the regulator thinks theworld's richest company must pay back years of allegedly illegal tax breaks.
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News Analysis: The EU's Vanishing Withholding Tax Regimes -- Part II

The authors conclude their review of the Court of Justice of the European Union's ongoing scrutiny ofwithholding taxes imposed by member states on cross-border financing arrangements. Thisweek they look at the Court's treatment of interestwithholding under the EU and European Economic Area guarantees of freedom to provide services.
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Fact-Checking Apples Claims on E.U. Tax Ruling

by Katie Banner (The New York Times)
Timothy D. Cook, Apple's chief executive, issued a defiant letter to his European customers on Tuesday after the region's antitrust enforcer ordered Ireland to collect 13 billion euros, or about $14.5 billion, in back taxes from the company.
We examined some of the points Mr. Cook made in the letter, consultingwith five tax experts to fact-check the chief executive's statements.while Mr. Cookwas technically truthful, he omitted some context and shifted the spotlight from the thrust of the European Commission's case:whether Apple took advantage of loopholes in Irish tax laws.
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Apple Owes $14.5 Billion in Back Taxes to Ireland, E.U. Says

  • By Kanter James and Mark Scott
by James Kanter and Mark Scott (The New York Times)
The European Union on Tuesday ordered Ireland to collect $14.5 billion in unpaid taxes from Apple, a record penalty thatworsened tensionswith the United States over the bloc's crackdown on sweetheart dealswith global multinationals.
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Brexit May Make U.K. More Attractive to Multinationals After EUs Apple Ruling

by Jason Douglas (Thewall Street Journal)
In theory, quitting the European Unionwould free the U.K. from the sort of EU oversight that on Tuesday resulted in Brussels ordering Ireland to recoup some 13 billion euros ($14.5 billion) ofwhat it called unpaid taxes from one of its biggest multinational investors, Apple Inc.
That, and the country's low corporate-tax rate, could burnish post-Brexit Britain's allure for multinational companies, provided it maintains a high degree of access to the EU's huge single market for goods and services, tax experts said.
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EU Apple Tax Ruling Stirs Fears of Revenue Loss in U.S.

by Richard Rubin (Thewall Street Journal)
American politicians have spent years salivating over U.S. companies' stockpile of untaxed foreign profits, now more than $2 trillion and growing.
Europe got to that money pot first.
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Europes Apple Tax Ambush

  • By The Wall Street Journal
by Thewall Street Journal
Even by the usual Brussels standards of economic malpractice, Tuesday's 13 billion euro ($14.5 billion) tax assault on Apple is something to behold. The European Commission decided that Dublin's application of Irish tax law to an American company violated European antitrust rules. Orwellwould understand.
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Apple owes $14.5 billion in back taxes, European authorities say

by Renae Merle (Thewashington Post)
European authorities ruled Tuesday that Apple owes more than $14.5 billion in back taxes after striking a sweetheart dealwith Ireland that allowed the tech giant to underpay for more than a decade.
Apple paid a tax rate of 1 percent or even less - 0.0005 percent, in some years - on its European profits, according to the European Commission,which launched an investigation into the company's international tax strategies in 2014. That arrangement, according to the commission, is illegal because it amounts to an improper incentive under European rules.
The ruling is likely to rattle many U.S. corporate boardroomswhere aggressive tax strategies have become standard practice.
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How the E.U.s ruling on Apple explains why Brexit happened

by Max Bearak (Thewashington Post)
The governing body of the European Union ruled Tuesday that one of its members, Ireland, had broken its rules by allowing U.S.-based Apple to pay a tax rate of 1 percent - and sometimes as little as 0.0005 percent. Ireland's regular tax rate is 12.5 percent, and the E.U.'s rules state that members cannot give special benefits to individual companies, even if the entity in question is the most highly valued company in theworld.
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House and Senate Taxwriters Denounce Apple State Aid Ruling

by Dylan F. Moroses (Tax Notes)
House and Senate taxwriters voiced their frustration andworry about the European Commission's announcement August 30 that Ireland must collect ÔøΩ13 billion in illegal state aid it provided to Apple over a decade through tax rulings.
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Clearinghouse Systems Not Ready for Dividend Equivalent Rule

Bloomberg

by Allyson Versprille
The effective date for the IRS's dividend equivalent payment rules should be postponed a year to give clearinghouses enough time to bring software systems up-to-date, two groups said.
The Internal Revenue Service issued final and temporary regulations (T.D. 9734) under tax code Section 871(m) in September 2015. The rules governwithholding on certain notional principal contracts, derivatives and other equity-linked instrumentswith payments that reference dividends on U.S. equity securities. The guidancewas aimed at stopping foreign investors from skirting the U.S.withholding tax.
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Ryan: EU's $14.5B tax ruling against Apple 'awful'

House Speaker Paul Ryan (R-Wis.) on Tuesday ripped the European Union's "awful" determination that Apple should pay Ireland $14.5 billion in back taxes.
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Brady Statement on the European Commissions Multibillion-Dollar Tax Bill to Apple

byKevin Brady (Ways and Means)
Today Houseways and Means Chairman Kevin Brady (R-TX) released a statement after the European Commission's decision seeking to impose a multibillion-dollar tax bill on Apple, Inc.
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Apple's in a Cage Fight on Tax

by Leila Abboud (Bloomberg)
The European Commission just turned taxation of multinational companies into a cage fight and put U.S. firms on notice that the oldway of negotiating dealswith individual countries is no longer a sure thing.
Expect some unintended, and unwelcome, consequences.
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Apple Ireland Ruling Could Be the End of Easy European Tax Deals

by Alexwebb and Adam Sarariano (Bloomberg)
The dayswhen big U.S. technology companies could easily slice tax bills in Europe are coming to an end.
On Tuesday, European Competition Commissioner Margrethe Vestager sent the strongest signal yet that shewon't abide these strategieswhen she demanded Apple pay an estimated 13 billion euros ($14.5 billion) in back taxes.
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Could The EU's 'Apple Tax' Reboot Corporate Tax Reform In The U.S.?

by Howard Gleckman (Forbes.com)
For years, corporate tax reform in the U.S. has been dead in thewater, in part because of deep disagreementswithin the American business community overwhat such a restructuring should look like. But the European Union's increasingly aggressive effort to force its members to collect tax on U.S.-based multinationals has the potential to change that dynamic.
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The Growing Uncertainty in the International Tax System

by Scott Greenberg (Tax Foundation)
Earlier today, the European Commission announced that itwould require Ireland to collect roughly $14.5 billion in taxes from Apple, after determining that Ireland had granted Apple "illegal tax benefits" under the rules of the European Union.
Today's decision is one in a string of recent European Commission rulings about the taxation of American businesses that operate in Europe.
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Genevas Corporate-Tax Fight Becomes Mother of All Battles

by Albertina Torsoli and Dylan Griffiths (Bloomberg)
When the European Union pressured Switzerland to scrap tax breaks for foreign companies, Geneva had most to lose. Now, the canton that's home to almost 1,000 multinationals is set to use tax to burnish its appeal.
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European Commission finds that Ireland has granted unlawful State aid to Apple

  • By PwC

PwC

by PWC
In its press release issued on August 30, 2016, the European Commission announced the adoption of its final decision in the formal State aid investigation into the profit attribution arrangements and corporate taxation of Apple in Ireland. The Commission concluded that, in its opinion, Apple benefitted from unlawful State aid granted by Ireland, and it orders full recovery of the aid in an amount of up to ÔøΩ13 billion plus compound interest.
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Apple, Congress and the Missing Taxes

  • By The Editorial Board
by The Editorial Board (New York Times)
Apple and the United States are crying foul over the ruling in Europe that Apple received illegal tax breaks from Ireland and must hand over 13 billion euros ($14.5 billion), a record tax penalty in Europe.
But Apple and the United States have only themselves to blame for the situation.
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Dispute Resolution Landscape Becoming More Difficult, Practitioners Say

by Stephanie Soong Johnson (Tax Notes)
While conventionalwisdom says it's better to resolve tax disputes at an early stage, such as the audit level, it's becoming more difficult to resolve cases and remain confident in advance pricing agreements, especially in light of the controversial European Commission decision that Apple Inc. received illegal state aid, practitioners said.
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Ireland Ordered to Recover $13 Billion in State Aid From Apple

  • By J. P. Finet
by J.P. Finet (Tax Notes)
A 1991 advance pricing agreement issued to Apple affiliates by the Irish government may have artificially lowered the company's tax bill and resulted in as much as ÔøΩ13 billion in illegal state aid.
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Press Release: Has the European Commissions Apple decision signalled the beginning of the end of tax wars?

  • By Tax Justice Network
by Tax Justice Network
The European Commission's assessment of ÔøΩ13 billion in taxes due from Apple Inc. for 2003 through 2014 seems to alignwith German and U.K. calculations of amounts due, the Tax Justice Network said in an August 30 statement following the commission's decision on Irish state aid for Apple.
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Canada in Informal Talks With IRS on Further Joint Audit Work

by Stephanie Soong Johnson (Tax Notes)
After recent successwith a joint audit under their pilot program, the Canada Revenue Agency and the IRS are in preliminary, informal discussions about carrying out furtherwork in the same vein, according to a top Canadian tax official.
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News Release: U.S. Should Take a Page from European Commission's Book and Crack Down on Corporate Tax Avoidance

  • By CTJ Reports
by CTJ Reports (Citizens for Tax Justice)
Instead of questioning the validity of the European Commission's ruling on the state aid provided to Apple Inc., the U.S. should follow the commission's lead andwork to eliminate corporate tax avoidance, Matthew Gardner of the Institute on Taxation and Economic Policy said in an August 30 statement released by Citizens for Tax Justice.
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ATF Applauds European Commission Action Against Apple and Ireland

  • By Americans for Tax Fairness
by Americans for Tax Fairness
The European Commission's decision ordering Ireland to recover ÔøΩ13 billion in illegal state aid from Apple Inc. is a strong stand against secret tax deals, and the Treasury Department should pursue its own legal claims against Apple for tax dodging and profit shifting, Frank Clemente of Americans for Tax Fairness said in an August 30 release.
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On Apple, U.S. Should Follow Europes Lead Level Playing Field for Small Business to Compete

by Clark Gascoigne (Fact Coalition)
Congress and Treasury should follow Europe's example and level the tax playing field for small businesses, the Financial Accountability and Corporate Transparency Coalition said in August 30 comments on the European Commission's decision that Ireland granted Apple illegal state aid through tax rulings.
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APAs More Efficient After New Efforts: Canadian, U.S. Officials

Bloomberg

by Alex M. Parker
Officials from the Canadian and U.S. tax authorities said front-loading the information-gathering process for their advance pricing agreement programs has helped make the process smoother and quicker.
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Appeal of APAs Fades in Light of EU State-Aid Rulings

Bloomberg

Corporations considering advance pricing agreementswith tax authorities in the European Union mightwant to think twice in light of judgments against Apple Inc. and other multinationals, practitioners say.
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Apple's $14.5 Billion EU Bill May Pressure U.S. on Overhaul

Bloomberg

by David Kocieniewski and Lynnley Browning
The European Union's finding that Apple Inc. owes Ireland more than $14 billion in back taxes reveals the high cost the Treasury Department may pay by failing to keep pace in a global effort to stem corporate tax avoidanceÔøΩand Apple might represent only the first major U.S. loss.
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A Battle Against Base Erosion: D.C.'s Chainbridge' Saga

Bloomberg

by Dolores Gregory
In the second article of a two-part series, Bloomberg BNA looks at the obstacles confronting states as they combat abusive transfer pricing. This article focuses on the efforts undertaken by the District of Columbia to combat revenue losses through its contractwith economic consulting firm Chainbridge Software LLC.
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5 takeaways from the EU's blockbuster ruling against Apple

The European Commission has ordered Apple to pay Ireland 13 billion euros ($14.5 billion) for its tax dealings in a case that is being closely followed inwashington and by the business community. @

The European Union's executive arm ordered the payout on the grounds that Apple had received unfair state aid from Ireland in the form of tax rulings that allowed the tech giant to pay very little in taxes on its profits from European sales. According to the Commission, such aid came in violation of European Union regulations that prevents member states from granting special tax provisions to companies.@

Here are five things to know about the ruling. @

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The Apple tax ruling - what this means for Ireland, tax and multinational

by Simon Bowers (The Guardian)
The European commission has ordered Apple to pay back the Irish state up to ÔøΩ13bn in taxes in a landmark ruling. Apple paid a tax rate on European profits of between 0.005% and 1%, according to the EU's executive arm. The US technology group, and Ireland, have said theywill appeal against the decision but itwill have ramifications for countries and companies across Europe.
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Apple holds Europe to ransom: Tech giant threatens to cut jobs in EU after Brussels orders it to pay back £11BILLION in tax over 'illegal' sweetheart deal with Irish government

by Martin Robinson (Daily Mail)

Apple has already threatened to cut jobs in Europe after Brussels ordered it to repay £11billion ($14.5billion) - the biggest tax bill ever imposed outside the US. The European Commission's three-year investigation into Apple's sweetheart dealwith Ireland has found it amounted to illegal state aid. Its damning report published today says the tech giant paid as little as 0.005 per cent tax by funnelling its non-US profits through its Irish headquarterswith no staff or premises then on to its $178billion (£120bn) offshore fund.¬Å@

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Statement by Commissioner Vestager on state aid decision that Ireland's tax benefits for Apple were illegal

  • By Commission Eurpeenne

by Commission Eurpeenne

The European Commission has today adopted a decision that Apple's tax benefits in Ireland are illegal.@

Two tax rulings granted by Ireland have artificially reduced Apple's tax burden for over two decades, in breach of EU state aid rules. Apple now has to repay the benefitsworth up to �13 billion, plus interest.@

To read more go here

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US taxpayers could end up covering Apple's back taxes in Ireland

by Rick Newman, (Finance Yahoo)
European authorities have clamped down on a special deal between Apple and Irish tax authorities, saying the arrangement uniquely favors Apple and is unavailable to other companies. Nixing the dealwill force Apple to pay taxes in Ireland at the higher rate other companies pay. The bill: about $14.5 billion.
But Apple may get reimbursed for all of that by an unlikely benefactor: the US taxpayer.
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Apple Finds Out It Took the Tax Game Too Far

by Justin Fox (Bloomberg)

Youwant your multinational corporation to be seen as a good corporate citizen. But you also feel obliged to your company's shareholders to keep it from paying a cent more in taxes than it is required to.@

Sowhat's the dividing line beyondwhich responsible tax management turns into poor citizenship? @

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Applefs Tax in Ireland

  • By Wall Street Journal

bywall Street Journal

The European Union said Apple Inc. owes billions of dollars in unpaid taxes to Ireland ​after it ruled on Tuesday that a dealwith Dublin allowed the company to avoid almost all tax ​on profits ​across the entire bloc for more than a decade.@

Here'swhat to know about the ruling.@

To read more go here

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EUfs Apple Tax Hit: Ire In Ireland, Confusion Elsewhere

by Stephenwilmont (Wall Street Journal)

The startling thing about the European Commission's ruling against Apple's Irish tax bill is how few people it pleases.@

You might think the Irish governmentwould be grateful for extra fundsworth up to �13 billion ($14.5 billion)�a figure equivalent to about 30% of its total tax receipts last year. This could be seen as a chance to recoup some of the estimated �43 billion controversially spent on bailing out banks in thewake of the 2008 financial crisis.@

But Irish Finance Minister Michael Noonan "disagrees profoundly"with the Commission. He evidentlywants to maintain the jobs and income tax associatedwith his country's reputation as a tax-efficient base for multinationals.@

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