Int'l Tax News

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Economists Launch Global Tax Plan for Pandemic Recovery

  • By Amanda Athanasiou

COVID-19 economic recovery plans should include a minimum corporate tax rate andwealth taxes, according to a new report,whichwarns against bailouts for tax avoiders and a continued race to the bottom.

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Can the WTO Stop the Race to the Bottom? Tax Competition and the WTO

  • By Martin Vallespinos

University of Michigan Law School Professor Martin Vallespinos analyzes the interaction between income tax competition and the multilateral trade regime. He argues that forms of tax competition distort international trade and should be policed. However, he doesn't believe the international tax regimewill be able to cure the ill due to collective action issues. Professor Vallespinos also discusses steps thewTO can take toward modernization to police tax competition measures.

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Design of Scope Limitations for OECD Pillar 1 Work

  • By Itai Grinberg

In thiswhite paper, the author proposes a quantitative method to efficiently limit the scope of multinational enterprises towhich theOECD's pillar 1 amount A reallocationwould apply.

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OECD Wants Taxpayer Input on COVID-19 Transfer Pricing Issues

  • By Ryan Finley

In a questionnaire issued to business group members, theOECDhas called for taxpayers to explain the transfer pricing compliance challenges caused by the COVID-19 crisis and to identify any issues that require clearer guidance.

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Beyond Digital: Is Cryptocurrency the Next Tax Frontier?

  • By Mindy Herzfeld

Mindy Herzfeld examines the paucity of IRS guidance on digital currency and the confusion that creates.

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Global Tax Talks Waver as Pandemic Hits Government Coffers

  • By Paul Hannon and Richard Rubin
Worldwide revenue collections are down. Tech companies are prospering. That combination is roiling international tax negotiations.
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Insight: Covid-19 and the Future of TaxationWhat Role for Cooperative Compliance?

  • By Jeffery Owens

The author suggests that the disruption caused by Covid-19 may provide an opportunity to adjust theways inwhich multinational enterprises and tax administrations interact, by the use of cooperative compliance programs.

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Insight: U.S. Investigation of Digital Services TaxesWill It Affect Multilateral Negotiations at OECD?

  • By Jefferson Vanderwolk
In light of the U.S. Trade Representative's recent announcement of new investigations regarding digital services taxes that have been enacted or proposed by several countries, the author examines the effect of the investigations on the ongoing OECD efforts to develop a multilateral policy on taxing the digital economy.
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U.S. Blocking Digital Tax Agreement at OECD, Le Maire Says 

  • By Isabel Gottlieb
A global agreement on a version of the OECD's plan to tax the digital economy should be possible by the end of this year, but the U.S. still has to be convinced, the French finance minister said Thursday.
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Trump Administration Escalates Global Fight Over Taxing Tech 

  • By Jim Tankersley and Ana Swanson
The U.S. investigation targets nine countries, plus the European Union, that have adopted or are considering new taxes thatwould hit American companies like Google and Amazon.
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U.S. Weighs Tariffs Against Nations Seeking to Tax Internet Firms

  • By Josh Zumbrun

The Trump administration is taking the initial step to prepare tariffs against a range of trading partners unless they back off proposals to impose taxes thatwould fall heavily on the major American internet companies.

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India Is Said to Defend Digital Tax as U.S. Starts Probe

  • By Shruti Srivastava

Indiawill defend its decision towiden a tax on digital services after the U.S. started a probe to determinewhether the policy discriminates against American tech giants, a personwith the knowledge of the matter said.

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France Pushes Back Against U.S. Over Digital Tax Probe

  • By William Horobin

France slammed the U.S. over its probe into digital taxes that are being considered by a number of countries, saying it contradictswashington's call for unity among leading economies.

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Taxation for a New 'New Deal': Short-, Medium-, and Long-Term Options 

  • By Reuven S. Avi-Yonah
Professor Reuven S. Avi-Yonah discusses governments' need for new sources of revenue to offset its costs and build a better social safety net during the Covid-19 pandemic. He believes that in the short term (1-5 years), governments need to rely on immediate solutions like excess profit taxes (EPTs) on companies that benefit from the pandemic and digital services taxes (DSTs) to capture some of the increase in the use of such services that may escape regular income and consumption taxes. In the medium-term (5-10 years), governments should permanently increase taxes on the rich and on corporations to address the inequality that is likely to be exacerbated by the pandemic, and adopt carbon taxes to mitigate climate change. In the long term (10 years and more), new and innovative sources of revenue may emerge like taxes on artificial intelligence, bit taxes, financial transaction taxes, and others. Further, he argues governments of countries like the US that lack a VAT should adopt one.
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U.S. Weighs Tariffs Against Nations Seeking to Tax Internet Firms (1)

  • By Josh Zumbrun
The Trump administration is taking the initial step to prepare tariffs against a range of trading partners unless they back off proposals to impose taxes thatwould fall heavily on the major American internet companies.
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Southeast Asias Largest Economy Readies Digital Goods Tax Rule 

  • By Tassia Sipahutar

Indonesia's government is preparing a regulation to enable it to collect a 10% value-added tax on digital products from August, matching a similar levy already imposed on physical goods.

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New EU Tax Proposals Later if OECD Talks Fail, Top Official Says

  • By Stephen Gardner

The European Commission could propose an EU-wide digital services tax and a minimum tax on multinationals in 2021, the bloc's top tax official said Thursday.

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Insight: DAC6Past, Present, and Future

  • By Keith Brockman

The EU doesn't appear inclined to extend the DAC6 reporting deadlines for tax-motivated transactions despite the Covid-19 pandemic, the author outlines the evolution, hallmark principles, best practices, and possible future trends for the measure.

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Digital Services Tax: A Cross-Border Variation of the Consumption Tax Debate 

  • By Young Ran (Christine )Kim
Professor Christine Kim's articlehighlights DST as a consumption tax and provides normative implications for policymakers deliberating a DST. She argues that a DST,with certain modifications, can be a good solution for the tax challenges of the digital economy.
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The Transformation of International Tax

  • By Ruth Mason
The recession of 2008 precipitated a political crisis that motivated an unprecedented international project to curb corporate tax dodging. Professor Ruth Mason argues, contrary to dominant scholarly views, that this effort transformed international taxÔøΩchanging its participants, agenda and institutions, norms, and even its legal forms. Perhaps most important, efforts to close corporate tax loopholes opened a rift over the resulting revenues that threatens a hundred-year-old tax treaty framework. This Article identifies and critically evaluates these changes from the perspectives of revenue, inclusivity, legitimacy and accountability, innovation, and durability.
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Saving the Planet by Cutting Corporate Taxes: A Comparative Case Study Analysis 

Professors Robert Mann, Fiona Martin, and Bill Butcherseek to fill the research gap between the global trend of corporate tax rate cuts and the influence of corporate environmental social responsibility by making a qualitative inquiry into the interaction between effective corporate tax rates, corporate tax cuts, and corporate social responsibility.They argue that the role of for-profit corporations should not be limited to making short-term profits for their shareholders; if corporations benefit from corporate tax reductions, some of that benefit should be sharedwith society.
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It's All About the DRD, What's Wrong with Foreign Branches, and a Few Other Things You Should Know About the New International Tax Provisions 

  • By Rebecca Rosenberg
Ohio Northern University Professor Rebecca Rosenberg reviews the new international tax rules passed under the TCJA.
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OECD Minimum Tax Proposal Could Lead to Quadruple Taxation 

  • By Hamza Ali

The OECD'swork on creating a global minimum business tax rate is still in danger of creating double taxation, according to a European bank's tax director.

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EU Calls Out Six Member Countries on Aggressive Tax Planning

  • By Stephen Gardner

Lack ofwithholding taxes on payments leaving Hungary and high royalty and dividend payments in Ireland are among theweaknesses of EU member countries' tax frameworks, the European Commission saidwednesday. The commission highlighted six countries in its regular European Semester review of the bloc's national economic policiesÔøΩCyprus, Hungary, Ireland, Luxembourg, Malta, and the NetherlandsÔøΩwhere it said loopholes should be closed to prevent aggressive tax planning.

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U.S. Tax Treaties Will Interpret NAFTA References as USMCA

  • By Rossella Brevetti

Any references in tax treaties to the North American Free Trade Agreementwill be interpreted as references to the U.S.-Mexico-Canada Agreement once that pact takes effect, the Internal Revenue Service said Tuesday.

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The Case Against Tax Subsidies in Innovation Policy

  • By Charles Delmotte

While intellectual property (IP) scholars propose replacing IP rightswith tax subsidies for firms that invest in research and development (R&D), NYU School of Law Professor Charles Delmotte argues that information problems concerning the operationalization of tax subsidies in the IRC are insurmountable.

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Companies Start Reaping Billions in Tax Breaks to Help Ride Out Slump

  • By Richard Rubin and Theo Francis
New tax breaks expected to total about $650 billion are starting to flow to U.S. businesses, giving them quick cash and longer-term help to ride out the economic downturn.
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Firms That Left U.S. to Cut Taxes Could Qualify for Fed Aid

  • By Laura Davison
American companies that moved their official headquarters offshore to avoid U.S. taxes could qualify for coronavirus aid from the Federal Reserve, tax lawyers say, raising new questions aboutwhich firms should get access to public money.
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States Swiveling to Pandemic Pause Plans to Tax Foreign Income 

  • By Michael J. Bologna
Multinational corporationswill have towait longer to find out how stateswill tax their offshore earnings as legislatures pivot to handling the public health crisis.
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U.K. Accounting Body Calls for Scrutiny of Tax Haven Companies 

  • By Michael Kapoor
A leading U.K. accounting body is calling on the government to consider barring coronavirus aid to companies that use tax havens.
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COVID-19 and Us Tax Policy: What Needs to Change? 

  • By Reuven S. Avi-Yonah¬†
Professor Reuven S. Avi-Yonah discusses some short-term effects of the pandemic and then some potential longer-term effects on US tax policy.
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Entrepreneurs Legal Status Choices and the C Corporation Survival Penalty

  • By Emily Satterthwaite¬†

Using awide data set from an eight-year survey of nearly 5,000 businesses, Professor Emily Satterthwaite of the University of Toronto Faculty of Law, seeks to answer the question, have C corporations underperformed as compared to similarly situated businesseswith alternative legal statuses?

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Insight: Questions (and Answers) on the Status of the OECDs Work on Pillars 1 and 2

  • By Jeff VanderWolk

The author answers five questions onwhat the OECD is doing and not doing andwhat goals and expectations are and are not realisticwith regards to tax digitalization.

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Illusions of Justice in International Taxation 

  • By Adam Kern
The author criticizes the commonway of thinking about justice in international taxation,what the author refers to as the Capture Principal, the idea that each state should have the right to tax income generated from economic activitieswithin its territory.This criticalwork reveals an interesting new research agenda for thinking about justice in international taxation.
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Spain Wants EU Virus Response to Combat Unfair Tax Policy

  • By Janna Brancolini

Spain is planning to tell EU leaders thisweek that the bloc's response to coronavirus should include tax harmonization between members and the eradication of unfair tax practices.

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Insight: Getting to Grips with Global ImmobilityInternational Home Workers

  • By Andrew Kelly

The author looks at the international employment tax, social security, and corporate tax considerations of employees' variedworking from home arrangements due to the Covid-19 crisis.

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Insight: OECDs Analysis of Lockdown-Related Tax Treaty Issues Raises Interesting Questions

  • By Brad Clements and Jeff VanderWolk

The authors look at issues raised by the OECD's recent Model Tax Treaty guidance addressing tax issues arising from travel restrictions and stay-at-home orders.

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Insight: OECD Digitalization ProjectTax Multilateralism in the Aftermath of the Pandemic 

  • By Will Morris

The author postulateswhat the newworld of international taxwill look like in thewake of COVID-19 and examines the likelihood and dubiouswisdom of the inclination of national governments to tax "the other."

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Pandemic Disruptions Could Throw Tax Agreements into Limbo

  • By Hamza Ali

Teaser: Companies forced to change their business structures in thewake of the coronavirus pandemic may find it harder to renegotiate their agreementswith tax authorities, potentially opening them up to future disputes and audits.

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U.K. Parliamentary Committee Waves Digital Tax Through

  • By Stephanie Soong Johnston

AU.K. House of Commonscommittee has greenlighted Finance Bill 2020 provisions introducing a digital services tax, but itrejected a proposed amendment thatwould have required the government to report annually on the tax's operation.

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Czech Ruling Coalition Agrees to Cut, Delay Proposed Digital Tax

  • By Stephanie Soong Johnston

The Czech Republic's ruling parties intend to cut the rate of a proposed digital services tax by 2 percentage points and delay its effective date until 2021 as part of a new coalition agreement.

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COVID-19 Crisis Draws Tax Agencies Focus to Foreign Investors

  • By Annagabriella Colon

Governments are expected to focus on tax collections from multinational corporations and foreign investors like private equity and real estate funds to alleviate the financial consequences of COVID-19, a tax practitionerwarned.

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EU Tax Plan Focuses on Environment, Digital Economy

  • By Sarah Paez

EU Tax CommissionerPaulo Gentiloni's upcoming tax action planwill include proposals on administrative cooperation and environmental taxes, aswell as pushing ahead to tax the digital economy if there is no OECD-approved solution.

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OECD Says Enviro Taxes Could Help With Post-COVID Debt

  • By Natalie Olivo

High public debt resulting from the novel coronavirus pandemic could cause countries to pursue taxation that addresses climate change as part of their efforts to increase revenue, the Organization for Economic Cooperation and Development said in a report publishedwednesday.

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Developing World Eyeing Digital Tax For Revenue Gap

  • By Alex M. Parker

As the coronavirus pandemic decimates government revenue across the globe, new taxes on digital commerceÔøΩonce mostly a focus in Europe and other countrieswith large marketsÔøΩare emerging in the developingworld.

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Tax Sector is Failing to Address Racism

  • By Anjana Haines

Anti-racist protests in the US andworldwide have brought attention to a global problem. Racism still exists in the tax sector and more needs to be done to tackle the issue.

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Malaysian Stimulus Plan Exempts New Foreign Investments From Tax

  • By William Hoke

Malaysia's governmentannounced a MYR 35 billion (around $8.2 billion) program to boost economic activity in thewake of the COVID-19 pandemic. One of its key featureswould provide long-term tax exemptions to foreign investors.

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U.K. Offers Assistance With U.S. Beneficial Ownership Register

  • By Annagabriella Colon

A U.K. lawmakerwho heads the United Kingdom's anticorruption efforts has shared key findings regarding its beneficial ownership register and offered to helpwith the development of a similar model in the United States.

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Source Countries Can Tax Offshore Indirect Transfers, Report Says

  • By Annagabriella Colon

Countries inwhich immovable property or other location-specific assets are situated can assess capital gains tax on offshore indirect transfers (OITs) of assets, according to a new report from the Platform for Collaboration on Tax (PCT).

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Czech Republic, U.S. May Form Working Group on Digital Taxation

  • By Stephanie Soong Johnston

The United States is expected to ask the Czech government to create a jointworking group on digital taxation after announcing a probe into the country's proposed digital services tax.

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