Int'l Tax News

Over the past couple ofweeks there has been a lot discussion about the value-added tax among those in the media and in certain policy circles.
For the Tax Foundation article, go here.

Here's a tax policy issue I humbly submit you should agreewith me on even ifwe have polar opposite views on taxation: an eroding tax base is a bad thing.
For thewashington Post article, go here.

In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication ofwhat's ahead on the global tax scene for American businesses, it should be number one on the legislative agendawhen Congress returns in January.
For The Hill blog post, go here.

The rich have long made the most of cross-border tax avoidance. Developing countries are hit hardest by this practice, but may benefit the least from efforts to tackle it
For the Public Finance International story, go here.

The Treasury Department and the Internal Revenue Service have outlined additional steps they are taking to reduce the tax benefits of corporate inversions, andwhen possible, stop the transactions from occurring.
For the Accounting Today story, go here.

The U.S. strengthened efforts to discourage corporate inversions by making the deals more difficult and limiting the benefits of the transactions, just as an iconic American firm considers shifting its legal address abroad to lower its taxes.
For the Bloomberg Business story, go here.

The Treasury Department and theInternal Revenue Serviceon Thursdayissued new rules aimed at discouraging American companies from moving their headquarters abroad in search of lowertaxrates.
Increasingly, American companies have been trying to reduce theirtaxliabilities through a tactic known as a corporate inversion -- buying smaller foreign competitors and using those purchases to move their headquarters to countrieswith more favorabletaxrates than the United States'.
For the New York Times story, go here.

A recent Australian ruling thatwent against Chevron reflects how thinking has evolved on transfer pricing, even though it turned on old tax law, a senior Australian Taxation Office official said.
"The profit shifting problem has evolved over time andwas one thatwas limited to price, and now I think is recognized and acknowledged as a function of structures," ATO Assistant Commissioner Michael Jenkins said Nov. 18 at a conference in Sydney. "It's a structural issue, not a pricing issue. And interestingly, therewas a flavor of that kind of thinking in the Chevron judgment."
For the DTR story, go here. (subscription required)

Treasury released its new anti-inversion notice on November 19, andwhile placing new limitations on potential inverters, the guidance continues in the same vein as last year's notice.
For the TNT story, go here. (subscription required)

There are no easy answerswhen it comes to cost sharing, an IRS official said in response to a question about the OECD's crackdown on "cash boxes" and its impact on cost sharing as defined under the tax regulations.

For the DTR story, go here. (subscription required)

The IRS issued new guidance to continue the government's battle against inversion deals that let U.S. companies move their addresses outside the U.S. to reduce taxesÔøΩguidance that is for the most part prospective, but signals the government's intense efforts to make these deals tougher and less attractive.

For the DTR story, go here. (subscription required)

Treasury on November 19 issued a fact sheet regarding corporate inversions.

For the fact sheet, go here.

Today, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued a notice that takes additional steps to reduce the tax benefits of – andwhen possible, stop – corporate inversions. U.S. companies are currently taking advantage of an environment that allows them to move their tax residence overseas to avoid paying taxes,without making significant changes in the nature of their overall operations. Last year, Treasury took targeted steps​ to address this issue, and this notice identifies additionalways to reduce the incentives to invert.
For the Treasury release, go here.

Treasury Secretary Jacob J. Lew delivered prepared remarks on a press conference call regarding Treasury's announcement on corporate tax inversions.
For the release, go here.

The Obama administration has unveiled new measures aimed at deterring tax-cutting corporate transactions such as Pfizer's potential $150bn deal to buy Dublin-based Allergan.

For the Financial Times story, go here.

The Treasury Department on Thursday released new rules to restrain U.S. companies from putting their addresses in foreign countries to reduce their tax bills.

The changeswill make it harder for U.S. companies to buy a company in one foreign country and locate the combined entity's address in a different country. They alsowould limit companies' maneuvers before a merger to make a foreign company look bigger and thus escape existing U.S. tax restrictions.

For thewall Street Journal story, go here.

Senate Finance Committee Ranking Member Ronwyden, D-Ore., today issued the following statement following the release of new anti-inversion guidance.

For the statement, go here.

Senate Finance Committee Chairman Orrin Hatch (R-Utah) today issued a statement after the U.S. Treasury Department announced new targeted guidance on corporate tax inversions:
For the statement, go here.

Houseways and Means Chairman Kevin Brady (R-TX) released a statement in response to a notice from the U.S. Treasury Department and the Internal Revenue Service (IRS) on measures to curtail corporate tax inversions.
For the statement, go here.

Ways and Means Committee Ranking Member Sander Levin (D-MI) issued a statement after the U.S. Treasury Department and the Internal Revenue Service (IRS) issued a notice that takes additional steps to curb corporate tax inversions.
For the statement, go here.

Treasury on November 19 issued a fact sheet regarding corporate inversions.

For the fact sheet, go here.

Today, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued a notice that takes additional steps to reduce the tax benefits of – andwhen possible, stop – corporate inversions. U.S. companies are currently taking advantage of an environment that allows them to move their tax residence overseas to avoid paying taxes,without making significant changes in the nature of their overall operations. Last year, Treasury took targeted steps​ to address this issue, and this notice identifies additionalways to reduce the incentives to invert.
For the Treasury release, go here.

Treasury Secretary Jacob J. Lew delivered prepared remarks on a press conference call regarding Treasury's announcement on corporate tax inversions.
For the release, go here.

The Obama administration has unveiled new measures aimed at deterring tax-cutting corporate transactions such as Pfizer's potential $150bn deal to buy Dublin-based Allergan.

For the Financial Times story, go here.

The Treasury Department on Thursday released new rules to restrain U.S. companies from putting their addresses in foreign countries to reduce their tax bills.

The changeswill make it harder for U.S. companies to buy a company in one foreign country and locate the combined entity's address in a different country. They alsowould limit companies' maneuvers before a merger to make a foreign company look bigger and thus escape existing U.S. tax restrictions.

For thewall Street Journal story, go here.

Senate Finance Committee Ranking Member Ronwyden, D-Ore., today issued the following statement following the release of new anti-inversion guidance.

For the statement, go here.

Senate Finance Committee Chairman Orrin Hatch (R-Utah) today issued a statement after the U.S. Treasury Department announced new targeted guidance on corporate tax inversions:
For the statement, go here.

Houseways and Means Chairman Kevin Brady (R-TX) released a statement in response to a notice from the U.S. Treasury Department and the Internal Revenue Service (IRS) on measures to curtail corporate tax inversions.

For the statement, go here.

Ways and Means Committee Ranking Member Sander Levin (D-MI) issued a statement after the U.S. Treasury Department and the Internal Revenue Service (IRS) issued a notice that takes additional steps to curb corporate tax inversions.

For the statement, go here.

Congress must permanently increase tax revenues from large corporations and end "loopholes" and "gimmicks" unavailable to small businesses, Sen. Elizabethwarren (D-Mass.) said at a National Press Club forum.
For the DTR story, go here. (subscription required)

Recent bipartisan international tax reform proposals under consideration in Congress received scathing criticism November 18 from Sen. Elizabethwarren, D-Mass.,who called deemed repatriation a "giantwet kiss" and the innovation box a "gift for lazy" U.S. companies that have moved their headquarters to lower-tax countries.
For the TNT story, go here. (subscription required)

To hear some presidential candidates tell it, if itwere suddenly easy from a tax standpoint for U.S. corporations to repatriate more than $2.1 trillion in overseas earnings, the moneywould be in the nextwire transfer home, giving the economy a jump-start like none before.
For the TNT story, go here. (subscription required)

"Additional targeted guidance" thatwould further deter and reduce the economic benefits of corporate inversionswill be coming later thisweek, Treasury Secretary Jacob Lew said November 18.
For the TNT story, go here. (subscription required)

The Treasury Departmentwill be issuing "additional targeted guidance" thisweek to cut back corporate inversions, Treasury Secretary Jacob J. Lew told lawmakers in a letter obtained by Bloomberg BNA.

For the DTR story, go here. (subscription required)

Northern Irelandwill cut its corporate tax rate to 12.5 percent in April 2018 to attract foreign direct investment and better competewith neighboring countries, including the Republic of Ireland.
For the DTR story, go here. (subscription required)

It iswell-documented that the Indian Government has been making efforts to promote a non-adversarial tax regime in India, but are taxpayers feeling a knock-on impact already?
For the ITR story, go here.

In prior articles,we've referenced military theoretician Carl von Clausewitz. Strangely enough, passages in his seminalwork "Onwar" have an effect on cross-border mergers and acquisitions of today.
The effect is not limited to the mega-deals that have been so prominent over the past two years. It touches middle-market M&A and even small deals. The population of middle-market and start-up companies is obviously far greater than large-cap companies. Given this, in terms of numbers as opposed to dollars, it is understandable that cross-border M&A is a bigger issue for the middle-market and small business.
For the Forbes story, go here.

The Treasury Department is preparing to release guidance thisweek in an effort to curb "inversions," a practice allowing U.S. firms to reduce their taxes by basing their operations overseas.
For The Hill story, go here.

The proposed new limitation on benefits article in the U.S. model tax treaty goes too far in reducing access to these tax pacts, and the government should narrow those restrictions, the New York State Bar Association Tax Section said.
For the DTR story, go here. (subscription required)

The European Commission's proposal for mandatory country-by-country tax reporting by companies and legislationÔøΩcoming in MarchÔøΩwill go beyond the OECD's base erosion and profit shifting plan and require that the details of taxes paid by companies in individual countries be public, a commission official said.
For the DTR story, go here. (subscription required)

Some of the most profitable technology firms in the U.S. have formed a coalition to push for a U.S. international tax overhaul in thewake of the OECD's completion of its action plan on base erosion and profit shifting.
For the DTR story, go here. (subscription required)

The OECD's base erosion and profit shifting (BEPS) reforms do not go far enough in changing the international corporate tax system, G20 leaders have been told.
In a letter to leaders at the G20 summit in Antayla, Turkey, Nobel Prize-winning economist Joseph Stiglitz and others from the Independent Commission for the Reform of International Corporate Taxation (ICRICT) said that,while a good start, reforms need to go much deeper to ensure multinational corporations pay their fair share.
For the Public Finance International story, go here.

Appearing before a special European Parliament tax rulings committee, representatives of multinational enterprises expressed support for the OECD'swork in crafting guidelines to combat base erosion and profit shiftingwhile defending their operations and voicing concernswith the public disclosure of information.
For thewWTDS story, go here. (subscription required)

In this report, Stone examines proposals by Treasury,whichwere releasedwithout a technical explanation, to modify the U.S. model treaty provisions that affect the limitation on benefits article.
Stone believes that given the rules-based nature of the LOB article, new rules are needed as taxpayers findways around the old ones and as the nature ofwhat Treasury believes to be treaty abusive -- such as low resident state tax treatment of income -- evolves. Stone discusses the provisions,with examples, and tries to make sense of them. In the end, he finds that the size and complexity of the LOB proposals suggest that a principal purpose test approach isworth considering.
For the Tax Notes special report, go here. (subscription required)

Google Inc. and Facebook Inc.were among U.S. companies facing questions from European Union lawmakers about their tax-reducing techniques, a month after regional antitrust regulators raised the stakes by ordering Starbucks Corp. and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes.

For the DTR story, go here. (subscription required)

Leaders from the Group of 20 nations endorsed the final results of the Organization for Cooperation and Economic Development's effort to combat corporate tax avoidance during their annual summit in Antalya, Turkey.
The G-20 members said the OECD's final base erosion and profit shifting action planwill help reach a "globally fair and modern international tax system," according to their Nov. 16 communique.
For the DTR story, go here. (subscription required)

Digital companies continue to get a rough ride from the EU. Hot on the heels of a European Commission decision to open an investigation into Google for allegedly breaching antitrust rules, EU lawmakers Monday targeted 11 companies ÔøΩ including Google, Facebook and Amazon ÔøΩ for their tax policies in Europe.
For the Politico story, go here.