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OECD Global Tax Overhaul Work on Track Amid COVID-19 Crisis
Despite the growing coronavirus pandemic, theOECDsecretariat is stillworking "full steam" ahead on a solution to update the international tax rules for the 21st century ÔøΩwhile using digital methods.
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EU to Ease State Aid Rules to Support Businesses
TheEuropean Commissionhas proposed thatbusinesses affected by the coronavirus be allowed to receive direct grants and selective tax advantages of up to ÔøΩ500,000 to address urgent liquidity issues.
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Trade Groups Seek Tariff Relief to Reduce Coronavirus Impact
Over 20 U.S. trade groups are calling on the Trump administration to eliminatesection 301tariffs, saying it is the onlyway to provide immediate relief from the financial burden of the coronavirus.
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Big 4 Firms Throw Their Weight Behind Altera's Supreme Court Bid
Three of theBig Four accounting firmshave added to calls forthe Supreme Courtto reviewAltera, arguing in an amici brief that the commensuratewith income standard cannot justify the 2003 cost-sharing regulations.
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Ireland Fears Corporate Tax Revenue Hit From OECD Proposals
Irish tax revenues reached their highest level last year at approximately ÔøΩ60 billion, but theOECD's international tax proposalswill increase uncertainty and volatility in corporation tax receipts in the coming years.
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Tech Giants Warn Supreme Court of Alteras Staggering Effects
Citing a $5 billion increase in aggregate tax liability following theNinth Circuit'sAlteradecision,Cisco Systemsand other high-profile tech companies have filed an amici brief supportingAltera's petition forSupreme Courtreview.
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Global Crises and Loss Planning
Using the coronavirus pandemic as a backdrop, Mindy Herzfeld reviews legislative and administrative actions during and since the 2008 financial crisis, noting that antiabuse tax ruleswritten in times of global profit and economic growth can have adverse effects in a downturn.
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Governments Worldwide Propose Tax Breaks to Counter Coronavirus
As the coronavirus extends its potentially deadly reach throughout theworld, severalcountries have announced tax and other measures to mitigate the economic impact from theCOVID-19disease.
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Polish Forum Endorses OECD Alignment on Transfer Pricing Methods
An advisory forum to thePolish Ministry of Financehas recommended that the country's new rules on transfer pricing methods be applied in accordancewithOECDguidance on the transactional net margin and resale-price methods.
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U.K. Budget Confirms DST Plans, Cuts Entrepreneurs Relief
The capital gains tax entrepreneurs' relief is expensive, ineffective, and unfair, U.K. Chancellor of the ExchequerRishi Sunakdeclared as he announced a substantial reduction in the lifetime limitwith immediate effect.
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The Arbitrary Foreign Tax Credit
ProfessorsJordan M. Barry and Ariel Jurow Kleiman discuss the development of the income tax limit to the foreign tax credit before describing the implementation and conceptual problemswith such a limit. They continue on to consider the arguments in favor of a narrow tax credit, before finally presenting the reform options for policymakers. Barry and Kleinman ultimately conclude that movingforward involves abandoning the credit's sharp, arbitrary distinction between pure income taxes and all other taxes.
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U.K. Holds Firm on Digital Tax in Virus-Dominated Budget
The U.K. government is maintaining its commitment to introduce a digital services tax in threeweeks.
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AstraZeneca Warns Public Global Tax Reports Could be Misread
Business groups and companies including AstraZeneca are pushing back against calls from U.S. lawmakers and advocacy groups to make corporate global tax reports public,warning that publishing such data could harm them.
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Insight: OECDs Alarm on Coronavirus and the World EconomyWhere Do Pillars 1 and 2 Fit In?
The author discusses how he believes the OECD's proposals under Pillars One and Two to increase corporate tax globally conflictwith the organization's recently issued economic assessment of the impact of the coronavirus on theworld economy.
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UK Gov't To Review Tax Regime For Funds To Boost Appeal
The government saidwednesday itwas looking forways to boost the attractiveness of the U.K. as a place for fund managers to establish themselves, including removing tax barriers that hold companies back from setting up.
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TCJA Transition Tax Raised $140B In 2017, IRS Says
More than 3,200 companies reported approximately $140 billion in tax obligations during 2017 related to the Tax Cuts and Jobs Act's transition tax provision, the Internal Revenue Service has reported.
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Public CbCR debate taken to the OECD
If the OECD adopts suggestions to align country-by-country reporting (CbCR)with the Global Reporting Initiative (GRI) standard public CbCRwill be inevitable, but this did not stop organisations expressing their opinions.
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EU Seeks Feedback On Measures To Fight Tax Fraud
The European Commission onwednesday asked for comments over the next fourweeks on an action plan to fight tax fraud as it prepares to make a more definite announcement in the summer.
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US, Mexico Renew Advance Tax Agreement For Manufacturers
The U.S. and Mexican tax authorities have renewed their agreement on a framework allowing more than 650 manufacturing companies to obtain certainty from the Mexican government about their taxes, an Internal Revenue Service official said Thursday.
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Brazil returns to the arms-length principle
As Brazil embraces OECD standards, many countries are moving in the opposite direction. This seismic shift in the largest South American economy could mean that Brazilwill remain an outlier in global tax policy.
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Amazon fights to overturn EU state aid ruling
The US technology company is battling against the European Commission's finding that its past cost-sharing arrangements in Luxembourg violated EU state aid law.
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The Fiat Appeal: Who Hijacked the Arms-Length Standard?
Robert Goulder examines the EU state aid case against Fiat and the implications it holds for Apple.
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Tech Groups Press Supreme Court to Review Altera
The financial and legal issues at stake inAltera Corp.'s cost-sharing challenge are too great forthe Supreme Courttowait for a circuit split, according to a group of trade and industry organizations.
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OECD Cancels Action 13 Public Consultation Amid COVID-19 Crisis
TheOECDhas called off an upcoming public consultation on its review of its country-by-country reporting standards under action 13 of the base erosion and profit-shifting project, citing growing coronavirus concerns.
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A Case for Higher Corporate Tax Rates 
The authors offer reasons to favor a higher rate and describe reforms that could help ease the adoption of efficient, higher taxes on corporate returns. They suggest that, at minimum, proponents of lower corporate tax rates present an incomplete picture and that the "lower corporate tax rates" conclusion is a non-obvious one.
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EU to Pursue Tax Overhaul if OECD Global Tax Rewrite Fails
The EU may try to harmonize corporate tax collection under a single set of rules if OECD-led talks to rewrite global tax rules fail, the bloc's tax commissioner said.
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Insight: Are You on the OECD Pillar One Black List? The Winding Road Ahead 
The OECD recently released a "blacklist" of industries thatwould be subject to a tax on global profit due to market intangibles, the author looks at the blacklist model, the U.S. reaction, opportunities for companies on the "whitelist," and theworkstreams to address controversial areas.
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U.S. Envoy Calls Unilateral Digital Taxes Self-Destructive 
The U.S. ambassador to Poland called unilateral plans to levy digital taxes on large tech companies "self-destructive" in an op-ed piece published March 1 by Rzeczpospolita, a major Polish daily.
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Real Effects of Private Country-by-Country Disclosure
Lisa De Simone and Marcel Olbert investigate the effects of mandatory private Country-by-Country disclosure to tax authorities on economic activity.They find evidence that firms affected by the disclosure mandate reduce ownership in tax haven subsidiaries relative to unaffected firms and increase their organizational transparency. They also observe that affected firms increasingly allocate revenue, employment, total assets, and, correspondingly, tax payments to subsidiaries in low-tax European countries.De Simone and Olbert concludethat mandatory CbC disclosure curbs the most aggressive tax planning achieved through tax haven operations but also affects the allocation of multinationals' real economic activities.
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Financial Transparency to the Rescue: Effects of Country-by-Country Reporting in the EU Banking Sector on Tax Avoidance 
Michael Overesch and Hubertuswolff analyze the effect of mandatory financial transparency on corporate tax avoidance. Their findings indicate that multinational banks increased their tax expense relative to other banks unaffected by the Country-by-Country Reporting mandate. Moreover, the authors found a stronger response by banks thatwere particularly exposed to the new transparency due to significant activities in tax havens. Overesch andwolff conclude that their results suggest that Country-by-Country Reporting can serve as an additional instrument for policymakers to curb corporate tax avoidance.
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Unintended Consequences of Eliminating Tax Havens
Juan Carlos Suárez Serratostudied a policy that limited profit shifting by US multinationals and shows it raised the tax cost of domestic investment. His research indicates that firms affected by the policy responded by reducing investment and domestic employment. Further, firm-level responseswere amplified to local labor markets through the established networks of profit-shifting firms; more exposed local labor markets experienced declines in employment, income, and home values and saw increases in government transfers. The author concludes that policy proposals that limit profit shifting should consider effects on economic activity in addition to tax revenue.
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Door Closed for New Companies to Join OECD Tax Compliance Pilot 
The OECD's second round of a pilot risk assessment programwon't accept more companies, for now, an IRS official said. The organization may, however, try to grow the program gradually in the future, Jennifer Best, director of the treaty and transfer pricing operations at the IRS's Large Business and International Division, said Thursday.
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EU Critical of Ireland, Others on Tax Avoidance Crackdown 
A handful of EU countries haven't made enough progress over the last year in tackling tax avoidance strategies used by multinational companies, the European Commission said in a package of annual reports.
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AI Comes to the Tax Code 
Governments are increasingly relying on machine learning and data analytics to analyze troves of data as they seek to detect tax evasion, respond to taxpayers' questions and make themselves more efficient.
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EU Antitrust Chief Defends Countries Digital Tax Measures 
EU antitrust and tech chief Margrethe Vestager defended European nations' plans to impose their own digital services taxes on large tech firms.
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U.K. Bound By EU State Aid Decisions Post-Brexit, Vestager Says 
The U.K. tax authority must complywith a 2019 EU decision on state aid even if EU rules stop applyingwhen the Brexit transition period ends, the EU's competition czar said.
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Some Countries Move on Digital Taxes Despite Talks, U.S. Threats 
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Insight: New OECD Guidance on Transfer Pricing Aspects of Financial TransactionsPart 1
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Insight: Should Multinational Enterprises Fear the Recent Successes of the J5?
The author discusses a new collaborative initiativebetween tax enforcement bodies in the U.K., U.S., Australia, Canada, and the Netherlands, known as the"Joint Chiefs of Global Tax Enforcement" (J5).
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Mnuchin Says Congress Key Hurdle to Europes Digital Tax Demands 
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House Bill Could Force Detailed Tax Reports From Multinationals 
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IRS to Stick to Proposed Tax Rate for Foreign Income Tax Opt-Out
The IRSwill stickwith an 18.9% offshore tax rate as the threshold for multinational companies looking to opt-out of a tax on a new category of foreign income, an agency official said.
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Spain to Tax Big Tech
Spain said itwill impose a digital-services tax on major tech firms such as Alphabet and Facebook, as part of its goal to tackle the country's deficit and encourage companies to pay taxeswhere they generate benefits.
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Beijings Soft Power Push on Global Tax
China's trillion-dollar Belt and Road initiative to build infrastructure connecting Asia, Africa, and Europe has generated plenty of headlines, but its tax arm remains little known. Companies and policymakers alike need to pay closer attention. The project could end up affecting how multinationals pay tax and resolve disputes around the globe.
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Heres How the EU Could Tax Carbon Around the World
The author discusses the European Union's plan for reducing carbon emissions from its factories and to prevent the rest of theworld fromwiping out those reductions and killing lots of European jobs at the same time.
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Turkey Faces Tax Blacklist If No Changes to Policy, Austria Says
Turkey has until the end of the year to complywith European Union demands on tax transparency, or else risk being added to a list of countries that could face financial sanctions, according to Austrian Finance Minister Gernot Bluemel. The rules include bilateral agreements to automatically exchange bank informationwith EU members,which include Cyprus.
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Insight: OECD's Preliminary Economic Analysis Highlights Need for Pillar Two Information and Engagement 
In light of the OECD's preliminary analysis, the author discusses the issue of double taxation under the proposed Pillar Two rules.
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European Union Proposes to Amend Council Directives for Administrative Cooperation in Tax Matters
The EU proposal includes measures thatwould expand existing information exchange and create new information disclosure rules.
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Insight: Pillar One of the OECD BEPS Action 1-The Ambitious Time-Bound Goals
The OECD intends to reach a consensus on the Inclusive Framework by the end of 2020. In light of that goal, the author examines the Framework's concepts, disparate interpretations, andwhat needs to be done to achieve a consensus.
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Practitioners Fear BEPS 2.0 Agreement May Not Be Good Enough
Even if international consensus is reached on a minimum tax regime and a new approach to allocating taxing rights, practitioners are concerned that dissatisfied countrieswill retain their unilateral measures or push for further reforms.