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After Altera, Services Regs May Be Next
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Overview: the European Parliament's work on taxation
The fight for fair taxation in the EU is high on Parliament's agenda following the revelations as a result of LuxLeaks and the Panama papers. At a timewhen EU countries are struggling to recover from the crisis, MEPs are pushing for greater transparency and an end to tax unfair practices. Read on for our overview of Parliament initiatives.
For the European Parliament release, go here.
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Investment Into U.S. Fueled by Tax-Driven M&As, Report Says
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Investment Into U.S. Fueled by Tax-Driven M&As, Report Says (1)
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News Analysis: Who's Afraid of Anti-Inversion Rules?
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Parliamentarians Compare BEPS Project Notes at OECD Meeting
EU and non-EU parliamentarians convened on May 2 at the OECD in Paris,where theywere briefed on the current state of play on base erosion and profit-shifting project implementation, andwere able to compare notes on their respective countries' experienceswith BEPS measures, attendees told Tax Analysts.
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The Huge Disconnect Between Congress and the Public on Business Tax Reform
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Thomson Reuters Releases Special Report on OECD''s Country-by-Country Reporting Requirements
Thomson Reuters Checkpoint has just released a special report addressing the European Commission's Anti-Tax Avoidance Package (ATA) and other global Country-by-Country Reporting (CbCR) developments designed in conformitywith the OECD BEPS Action 13 recommendations. The report,
BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting,will help multinational enterprises (MNEs) gauge their readiness to collect and aggregate the data required under CbCR andwill equip themwith the latest CbCR information to navigate this complex, quickly evolving landscape.
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We Need a Serious Approach to International Tax Reform
While the Obama administration touts its recent rules to limit corporate inversions as a step forward towards fixing our broken tax code, it is clear this administration fundamentally misunderstands the problems that are driving American companies abroad. In the long run, punitive Treasury Department regulationswill only make America less competitivewhile this administration ignores the core problem: a hopelessly outdated corporate tax code.
For theweekly Standard article, go here.
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Delaware's Opacity Industry Provides U.S. Onshore Tax Haven
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Inversion Rules Build Costly Wall for U.S., Brady Says
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Curb on 'Hopscotch' Loan Could be Expandesl, Official Says
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EU Study Recommends Reducing Incentives for Agggrssive MNE Tax Planning
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Cash Pooling Impact May Shrink in Earnings-Stripping Rules
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Time to Rewrite Transfer Pricing Rules After Altera'?
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News Analysis: Proceeding Directly to an Exit Tax
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News Analysis: Transfer Pricing Needs a Save Shot
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Germany, Others Questions Public Country-by-Country Reporting
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Professors Say International Tax System Changes Fall Short
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Intangible BEPS Risks
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The Post-BEPS World of Permanent Establishment
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Canadian Tax Agency Identifies Ruling for BEPS Exchanges
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Examining the Proposed U.S. Country-by-Country Reporting Regs
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When it comes to taxes, theres never been a better time to be a U.S. multinational
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Serial Borrowers From Cash Pools May Be Facing Equity Recast
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Tax authorities adapt to rise of e-commerce (1)
As tax authorities around theworld start to examine how e-commence sales affect their revenue from indirect tax it is important for taxpayers to knowwhat measures are being enforced.
For the ITR story, go here.
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Stack: IRS Working to Accept Early Country-by-Country Reports
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Debt-Equity Breakup Rule Sweeps in the World'
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Practitioners, Officials Hash Out Earnings Stripping Regs
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OECD Urged to Clarify How PE Definition Applies to Servers
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OECD Sees Roughly 100 Countries Adopting BEPS Changes
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Governments Urged to Use Transfer Pricing Values to Acquire IP
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Stack Calls for More MNE Engagement
by Ryan Finley
Treasury and the IRS areworking toward a solution to the "gap year" problem by allowing optional country-by-country reporting for 2016, but U.S. multinationals can help their own cause by engaging more in the global debate over corporate tax avoidance, according to Robert Stack, Treasury deputy assistant secretary (international tax affairs).
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Integration Plan Is Progressive but Aims to Be Revenue Neutral
A forthcoming corporate integration plan is showing signs that its current designwill raise revenue, but Senate Finance Committee Chair Orrin G. Hatch, R-Utah, said April 21 that hewants the final outcome to be revenue neutral.
For the TNT story, go here. (subcription required)
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Transfer Pricing Cannot Be Fixed
Tax reform proposalswon't fix our broken corporate tax system. Most proposals suggestwe lower the rates and broaden the base by removing tax expenditures and the interest deduction. Those proposals have merit and seem attractive, but they fail to fix the unfairness of domestic companies paying more tax than multinational enterprises in identical circumstances. This article examines two reform options outlined by Edward D. Kleinbard.
For the Tax Notes viewpoint, go here. (subscription required)
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It's Time to Revisit the Application of the CUT
In this article, Daniel Falk demonstrates that the requirements of the comparable uncontrolled transaction method regulations are virtually impossible to meetwhen strictly applied, and he discusses potential solutions to the problem.
For the Tax Notes viewpoint, go here. (subscription required)
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Boustany Seeks Clarity in Meetings on International Reform
Houseways and Means Tax Policy Subcommittee Chair Charlesw. Boustany Jr., R-La., said April 19 that hewill be meeting thisweekwith Republican committee members in order to seek clarity over how to proceedwith international tax reform.
For the TNT story, go here. (subscription required
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Cash Pooling Viability Debated Following Related-Party Debt Regs
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News Analysis: Inversion Regs Will Push States to Tackle Complex Questions
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News Analysis: Inversion Regs Will Push States to Tackle Complex Questions (1)
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Action 6 Draft May Deny Benefits Too Broadly, OECD Told
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Determining Basis and Other Tax Items of Foreigners
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Firms Need Tax Plan to Defend IP Hubs From China's Reach
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Sheltering Foreign Profits From U.S. Taxes Is No Big Feat
TheU.S. governmentchalked up a big victory this monthwhen it stopped pharmaceutical giantPfizer Inc. from mergingwithAllergan PLCand shifting its address overseas to avoid U.S. taxes.
But there is at least one thing the Treasury Department still can't do: force Pfizer to book taxes on $80 billion in foreign profits the New York-based company has socked away overseas.
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Treasury Hasn't Ruled Out Inversion Regs Expansion
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Officials Defend Inversion Regs' Lookback Periods
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Turkey introduces 'electronic place of business' concept
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Cash Pooling Under Microscope in Earnings-Stripping Rules