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Senate Committee Backs Bill to Deepen U.S. Economic Ties With Taiwan

  • By Alan Rappeport

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.

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It's Time for the United States to Move On From the DST Feud

  • By Ryan Finley

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.

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Some Open Questions on the U.N. Tax Cooperation Effort

  • By Nana Ama Sarfo

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

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US Backs Simpler Transfer Pricing Reform in Global Tax Deal

  • By James Munson

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.

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G-20 Leaders Call for Finalizing Pillar 1 Tax Treaty, Amount B

  • By Stephanie Soong

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.

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U.S. Trade Group Pans Canada's DST for Undermining OECD Process

  • By Sarah Paez

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.

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G20 Leaders Call for Transfer Pricing, Crypto Fixes in Tax Deal

  • By Danish Mehboob

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.

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Tech Groups Urge Canada to Drop DST and Refocus on OECD Tax Deal

  • By Stephanie Soong

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.

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European Commission Draws Lessons From Past Failures With BEFIT

  • By Elodie Lamer

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.

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Fixing or Nixing GLOBE

  • By Sol Picciotto

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.

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Global Minimum Tax to Reduce Low-Taxed Profit by 70%, OECD Says

  • By Lauren Vella

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.

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House Republicans Urge Germany to Repeal ‘Discriminatory’ IP Tax

  • By Samantha Handler

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.

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African Countries Seek to Craft Tax System for Whole Continent

  • By Lauren Vella

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.

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New Corporate Minimum Tax Ushers In Confusion and a Lobbying Blitz

  • By Alan Rappeport

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.

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BEFIT to Apply to Pillar 2 Groups, Align Transfer Pricing Rules

  • By Sarah Paez

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.

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Ireland Amends Patent Box in Response to Pillar 2 Rule

  • By Stephanie Soong

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.

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Tax Pros Fear High Court Will Go Too Far in Transition-Tax Case

  • By Isabel Gottlieb and Michael Rapoport

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. 

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Global Tax Deal and Taiwan Top Congress’ Fall Tax To-Do List

  • By Chris Cioffi and Samantha Handler

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.

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Pillar 2 and IP Boxes: A New Chance to Scrap a Flawed Policy

  • By Ryan Finley

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

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Did FDII Raise Revenue for the U.S. Treasury?

  • By Martin A. Sullivan

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.

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Technology Group Wants Amount B Extended to Digital Services

  • By Sarah Paez

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.

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Moore Outcome Could Mean a Whole Lot Less Revenue

  • By Jonathan Curry

Observers have long warned that an expansive Supreme Court decision in Moore v. United States could have catastrophic repercussions for the tax code. Now, the Tax Foundation has put a price tag on it.

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Italian Tax Reform Law Enabling Pillar 2 Adoption Goes Live

  • By Stephanie Soong

Italy’s new law enabling the government to implement sweeping tax system reforms has taken effect, paving the way for the transposition of the EU’s global minimum tax directive.

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FASB Approves Expanded Tax Disclosure Requirements for Companies Despite Opposition

  • By Mark Maurer

Companies will have to disclose more details about the income taxes they pay to government authorities under new requirements approved by the Financial Accounting Standards Board, a move to provide investors with greater transparency.

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German Coalition Agrees to Cut Corporate Taxes by €7 Billion a Year

  • By William Hoke

Germany’s ruling coalition has agreed to cut corporate taxes by approximately €7 billion a year to stimulate the economy and promote long-term investment during a slowdown in business activity.

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New Zealand Pushes Ahead With Digital Services Tax for 2025

  • By Stephanie Soong

The New Zealand government will soon propose legislation for a digital services tax, citing slow progress on an OECD global tax reform agreement aimed at addressing the tax challenges of the digital economy.

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Silicon Valley Asks IRS to Extend Foreign Tax Credit Relief

  • By Andrew Velarde

A prominent interest group representing scores of large multinational companies is asking the IRS to go further with its temporary relief from foreign tax credit rules that businesses have sharply criticized.

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Pillar 2 Tax Discourse Helps ASEAN Readiness, Ministers Say

  • By Stephanie Soong

A recent discussion among Association of Southeast Asian Nations members about OECD-brokered global minimum tax rules and their implications for investment incentives will help countries in the region prepare accordingly, finance ministers said.

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Tax Cropping Up in More Nontax Proposals

  • By Elodie Lamer

A draft European Parliament report states that taxation has a role to play in the insolvency framework, reflecting the growing presence of tax issues in nontax proposals at the EU level.

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Cruising the World With Pillar 2

  • By Mindy Herzfeld

Mindy Herzfeld takes another world tour to reexamine the latest developments in OECD pillar 2 implementation.

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Businesses Pushing Back on Design of Amount B Under Pillar 1

  • By Alexander F. Peter

Businesses digging into the details of the OECD’s public consultation document on simplifying the arm’s-length principle are pointing out critical gaps and open issues in amount B‘s design and asking questions about data transparency.

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OECD, Critics Spar Over Tax Deal’s Value for Developing Nations

  • By Lauren Vella

The OECD pushed back Thursday against criticism by tax advocacy groups that the 15% global minimum tax rules are too hard to administer and could be detrimental to developing countries.

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U.S. Tackles Crypto Tax Mess

  • By Richard Rubin
  • By Paul Kiernan

The federal government is escalating efforts to make cryptocurrency investors comply with tax law, nearly 15 years after people started trading bitcoin. The Treasury Department proposed new rules Friday to make it harder for crypto investors to dodge income taxes when they sell digital assets and to simplify complicated tax messes for people who are trying to follow the law.

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Switzerland Expects CHF 1.6 Billion From First Year of Pillar 2

  • By Sarah Paez

Switzerland expects to net CHF 1.6 billion (about $1.8 billion) from the first year of operation of its pillar 2 legislation, according to the 2024 budget.

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Portugal Transposes EU Directive on Country-by-Country Reporting

  • By William Hoke

Portugal has published a decree law transposing EU Directive 2021/2101, which requires member states to make country-by-country reporting mandatory for large multinational entities.

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Developing Nations Urged to Do Cost-Benefit Study of OECD Tax Deal

  • By Danish Mehboob

Two intergovernmental groups are advising developing countries to undertake a careful cost-benefit analysis of the OECD-led global tax deal.

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Pillar Two Questions for the US Can Result in Positive Answers

  • By Peter Barnes

Analyzing the OECD’s Pillar Two proposal that all countries impose a 15% minimum tax on corporate income is like playing a multidimensional chess game. Each element of the proposal, and each country that adopts it, creates waves that affect all other players, both governments and corporate taxpayers.

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New U.S. Buyback Tax Hits Companies With $3.5 Billion Burden

  • By Jennifer Williams-Alvarez

A new 1% tax on stock buybacks is starting to increase companies’ anticipated tax burdens, to the tune of over $3.5 billion in the first half of the year among the largest U.S. public companies.

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ASEAN Investment Ministers Call for Global Minimum Tax Review

  • By Stephanie Soong

Members of the Association of Southeast Asian Nations must review global minimum tax rules because they will only benefit developed countries and will adversely affect incentives offered by developing countries, investment ministers said.

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Critics of Biden’s Global Minimum Tax Deal Miss the Big Picture

  • By Rebecca Kysar

The US Treasury Department recently won hard-fought victories in the global minimum tax multilateral negotiations, which US lawmakers and stakeholders should applaud. Instead, some of them are now attempting to use that win against Treasury negotiators.

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Accounting Board Resists Backlash to Income Tax Reporting Plan

  • By Amanda Iacone

The US accounting standard setter said it would press on with a project that would force companies to detail the amount of income tax paid to state, federal, and foreign tax authorities. Companies would also be required to disclose the states, countries, and amounts paid if payments equal 5% or more of total tax payments.

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Five Years of CbC Reporting Yields Disappointing Results

  • By Martin A. Sullivan

Martin A. Sullivan argues that the IRS’s detailed data on five years of country-by-country reports don’t help provide a clear picture of multinationals’ profit shifting.

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China's Bid for International Tax Governance

  • By Nana Ama Sarfo

Nana Ama Sarfo looks at the evolution of China’s Belt and Road Initiative Tax Administration Cooperation Mechanism and questions whether it can meet its broad goals.

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Developing Countries Must Look Past Pillar 2, South Centre Says

  • By Stephanie Soong

Domestic minimum top-up taxes in line with the OECD’s pillar 2 plan won’t protect developing countries’ tax bases, but other options, like alternative minimum taxes, will, according to a South Centre policy brief.

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Developing Countries Say OECD Tax Rules Don’t Guarantee Revenue

  • By Lauren Vella

The 15% global minimum tax rules included as part of the OECD-led international tax deal favor developed nations, are burdensome to administer and do not guarantee the collection of more revenue, an advocacy group for developing nations said.

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German Cabinet Approves Draft Global Minimum Tax Legislation

  • By Stephanie Soong

Germany has finalized its proposed bill for transposing into domestic law the EU’s directive implementing global minimum tax rules under pillar 2 of an OECD-brokered international corporate tax reform revamp.

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EU Adopts CBAM Reporting Requirements

  • By Elodie Lamer

The European Commission has adopted rules governing reporting requirements during the phase-in of the carbon border adjustment mechanism. Several non-EU countries expressed concerns during the consultation on those rules.

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Czech Government Greenlights Global Minimum Tax Bill

  • By Stephanie Soong

The Czech Republic has approved draft legislation to transpose into its domestic law an EU directive implementing a global minimum top-up taxation framework under the OECD’s two-pillar corporate tax system overhaul.

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Global Minimum Tax May Add $629m to Vietnam State Budget: Report

  • By Linh Vu Nguyen

Vietnam’s finance ministry estimates the implementation of the global minimum tax may add about $629m to state revenue by 2024, news website Nhip Song reports, citing information from the Ministry of Finance.

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Rollback of Foreign Tax Credit Rules Helps Companies, For Now

  • By Michael Rapoport

For the moment, the government’s big rollback of foreign tax credit rules is a clear win for multinational drug makers, manufacturers, and companies doing business in Brazil. What happens next isn’t so clear.

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