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Crisis Recovery Tax Incentives Could Lead to BEPS 3.0

  • By Mattias Cruz Cano

As countries provide incentives to attract foreign investment, the OECD may have to readdress the BEPS framework in the post-COVID future.

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Moving to Formulary Apportionment Could Reduce Long-term TP Risks

  • By Josh White

Transitioning from the arm's-length principle (ALP) to formulary apportionment could mean fewer risks for taxpayers, but businesses should consider insuring transfer pricing (TP) risks during the transition.

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Lets Build on Cooperation for Digital Tax Deal, OECD Chief Says

  • By Stephanie Soong Johnston

Countries should build on the multilateral cooperation that made automatic information exchange possible in order to reach agreement on global corporate tax reform, theOECD's secretary-general told delegates at a key meeting.

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U.K. Parliamentarians Push for Greater Digital Tax Transparency

  • By Stephanie Soong Johnston

U.K. lawmakers have proposed several measures to ensure more digital services tax transparency, such as requiring in-scope companies to publish group tax strategies containing country-by-country data.

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Officials Warn 'Grim Future' Awaits Without Digital Tax Deal

  • By Stephanie Soong Johnston

If countries can't agree on a common approach to taxing the digital economy, then don't count on theworld to return to the status quo, EU andOECDofficials said.

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Global Tax Deal May Wait for U.S. Election

  • By Elodie Lamer

Countriesworking on an international solution to taxing the digital economy may bewilling towait for the outcome of the U.S. election as they continue talks on a global tax deal, theOECD's tax chief said.

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After the Break Up: Can Europe Build a Better DST?

  • By Robert Goulder

Robert Goulder examines the U.S.withdrawal from the OECD inclusive framework and possible next steps for the European digital services tax.

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Business Groups Rally Around OECD Global Tax Deal Work

  • By Stephanie Soong Johnston

Major business groups again voiced support for OECD-led talks on a global corporate tax reform deal, calling on governments, including the United States, to stay at the negotiating table and quickly reach an agreement.

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OECD Solicits Info on COVID-19 Transfer Pricing Issues

  • By Natalie Olivo¬†

The Organization for Economic Cooperation and Development (OECD) has asked companies and trade associations to comment on the transfer pricing issues they've experienced because of COVID-19.

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Constructive Engagement is Vital for Mutual MNE and Tax Authority Trust

  • By Anjana Haines

James Karanja, head of the Tax Inspectorswithout Borders (TIWB) Secretariat, tells ITR how multinational enterprises (MNEs) need to adapt as tax administrations gain auditing skills through TIWB initiatives.

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Tax Economists Double Down on Global Tax Multilateralism

  • By Danish Mehboob¬†

International Commission for the Reform of International Corporate Taxation's (ICRICT) Joseph Stiglitz has reemphasized the need for global tax reforms after the US pulled out of digital tax negotiationswith the OECD.

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COVID-19 Challenges for the Arms-Length Principle

  • By Jacob K Markham

In this article, the authors address the implications of the coronavirus pandemic for the arm's-length principle in the context of theOECD's inclusive framework.

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U.S. Withdrawal From Digital Talks Marks Collective Failure

  • By Elodie Lamer and Sarah Paez

The United States' decision to pull out of international negotiations on taxation of the digital economy has been metwith dismay fromEuropeanfinance ministers.

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U.S. Trade Representative Calls for Broad WTO Reform

  • By Annagabriella Colon

The United States has no plans to reverse its stanceregarding the need for significant reform oftheWTO,including a reset of tariff determinations,U.S. Trade RepresentativeRobert Lighthizersaid.

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U.S. Says OECD Talks on Digital Economy Have Hit an Impasse

  • By William Hoke

The United States has told key European countries thatOECDdiscussions regarding a global approach for taxing the digital economy have reached an impasse and thatwashingtonwon't accept even interim changes affecting U.S. technology companies.

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Europeans vow to pursue digital tax plans after US provocation

  • By Chris Giles

The EU has defied the US by vowing to pursue its own plans for digital taxes afterwashington pulled out of global negotiations on the matter and threatened to impose tariffs in retaliation against national levies.

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US Upends Global Digital Tax Plans After Pulling Out of Talks with Europe

  • By Chris Giles and James Politi

The US has thrown into disarray plans for a new global tax framework for technology companies after suspending talkswith European countries ÔøΩ andwarning them of retaliatory measures if they press aheadwith their own taxes.

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EU Blacklist May Force Changes in Private Equity Fund Structures

  • By Ryan Finley

Member states' enactment of measures that target countries on theEU's list of noncooperative tax jurisdictions maywarrant significant changes to the tax planning structures adopted by private equity funds, according to European tax practitioners.

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Groups Urge U.N. Tax Committee to Reconsider OECD Unified Approach

  • By Sarah Paez

TheU.N.tax committee should aid developing countries seeking tax revenue from the digital economy by rejecting theOECD's unified approach for modernizing corporate tax rules for the digital age, international civil society groups say.

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Making Sense of the New U.K. Global Tariff

  • By Robert Goulder

Robert Goulder breaks down the U.K. government's post-Brexit trade schedule.

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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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