Int'l Tax News

The United States officially entered into a tax treaty protocolwith Japan andwill enter into onewith Spain later this year, the U.S. Department of the Treasury said on Friday. The treaty protocolwith Japanwent into effect on Friday, and the onewith Spain is set to enter into effect on Nov. 27, the agency said in a statement.

The Organization for Economic Cooperation and Developmentis reviewing the Bulgarian tax authority's security measures following a massive data breach that included taxpayer information exchangedwith other countries through a global reporting system, the organization confirmed Friday. The July 15 breach,which according to news reports affected seven million Bulgarian taxpayers, is the first to involve the common reporting standard, a global initiative spearheaded by the OECD to exchange data about taxpayers in the hope of stemming illegal tax evasion.

By Raymond Colitt

Taxing thewealthy is becoming the latest sign of how Chancellor Angela Merkel's already-frail coalition is drifting apart, adding to the political turbulence as the economy teeters on the brink of recession.

By Isabel Gottlieb

A new French-U.S. digital tax deal did little to allay concerns that U.S. tech giants aren't ready to make their first tax payment in November.

By Aaron Junge, Karl Edward Russo and Peter R. Merrill

In this article, the authors examine the legal and economic issues surrounding a foreign minimum tax, setting out the consequences and administrative details of various design options.

By Elodie Lamer

With the aim of reviewing the energy taxation directive by the end of 2020, the European Commission's Directorate-General for Taxation and Customs Union is considering proposing qualified majority voting in tax matters.

By Amanda Athanasiou

Digital taxes and tradewars are potential factors in lackluster mergers and acquisitions activity across Europe in the first half of 2019, according to newly released data.

By Jad Chamseddine

The Tax Cuts and Jobs Actwas intended to be a comprehensive overhaul of the U.S. tax system, but a key piece coveted by multinationalswas left out and remains in flux as Congress mulls its future.

A global attempt by more than 120 countries to find away to more fairly tax global internet giants is moving ahead despite individual countries' deciding to impose their own tax, says the head of the international organization leading the project. Angel Gurria, secretary general of the Paris-based Organization for Economic Cooperation and Development, said Sunday at the Group of Seven summit in France that "whatwe are seeing is a very strong and a very clear signal ofwanting to find a multilateral solution."

Democratic presidential candidate Andrew Yang's new climate plan places stock in private sector investment and nuclear power to meet its emissions-cutting goals. According to a plan rolled out Monday morning, Yangwould invest billions in the private sector if elected to create technologies needed to curb carbon emissions, such as the creation of new nuclear facilities, and build electric grid resilience to achieve his goal of a "fully green" economy by 2049. Yang's proposal also calls for the establishment of a carbon tax, a concept few other presidential contenders have outright proposed.

French President Emmanuel Macron said Monday that his country and the U.S. have reached a "very good agreement" on France's digital tax. Macron said at a joint press conferencewith President Trump following the Group of Seven summit in France thatwhen an international tax on digital services is established, Francewill get rid of its national tax and companies that have paid France's digital tax "will be reimbursed."

By Tax Analyst

With Canada's federal election scheduled to take place on or before October 21, Conservative Party members arewarning that carbon taxeswill go up if the Liberal government is reelected ÔøΩ a claim the Liberals refute.

By Allison Christians

Allison Christians considers the late economist Peggy Musgrave and herwork's lasting influence on modern-day tax and public finance policy, especially regarding efforts to tax the digital economy.

By Stephanie Soong Johnston

As France cheered an agreementwith the United States to resolve tensions over its controversial digital services tax, trade groupswarned it could lead to more pain than gain for companies and tax authorities alike.

Bywilliam Hoke

A leading congressman in Mexico's governing party recently introduced legislation to amend VAT and income tax laws so that foreign companies providing digital services are considered to have a tax domicile in Mexico.

By Stephanie Soong Johnston

France intends to reimburse companies paying its digital services tax once a globally agreed approach on taxing the digital economy exists, a move that raises the stakes for ongoing negotiations, according to the OECD's tax chief.

By Ryan Finley

The Ninth Circuit's rejection of the IRS's valuation method in Amazon under old law may not affect new cost-sharing disputes, but its observation on later revisions raises other questions regarding the transfer pricing regulations.

By Alexander Kell

German Finance Minister Olaf Scholz backs the push by his Social Democratic party to reinstate awealth tax, according to an interviewwith Handelsblatt.

By Stephanie Bodoni

European Union judgeswill rule next month on appeals by Fiat Chrysler Automobiles NV and Starbucks Corp. against decisions ordering them to pay allegedly illegal tax subsidies.

By Hugo Miller and Stephanie Bodoni

In Prime Minister Boris Johnson's post-Brexit vision of a dynamic economy unshackled from the European Union, depressed British port citieswill come roaring back to life as tax-exempt free ports. A concrete bunker on the edge of Luxembourg's airport provides a useful reality check.

By Viriya Singgih and Tassia Sipahutar

Indonesia expects a reduction in income tax on gains made from securities backed by projects and property to help finance part of the billions of dollars it needs to build new airports, roads and railways.

By Siddhartha Singh and Siri Bulusu

India may soon roll back an additional levy on foreign funds and announce other measures to boost economic growth, a government official said in comments that helped the stock and currency markets reverse losses.

By Carrie Brandon Elliot

Carrie Elliot describes how new proposed regs allow taxpayers to elect an exclusion from global intangible low-taxed income for controlled foreign corporation's high-taxed income.

By Rogerio Abdala Bittencourt Jr. and Antonio José Ferreira Levenhagen

In this article, the authors discuss how Brazil can align its tax ruleswith international standards in the areas of fiscal and financial secrecy, tax evasion, avoidance, and aggressive tax planning in preparation for accession to the OECD.

By Reuven S. Avi-Yonah and Kimberly A. Clausing

In this article, the authors argue that the United States should consider adopting sales-based formulary apportionment and applying it to all large enterprises because it is more likely to lead to a stable outcome than recent OECD proposals and has important advantages relative to other proposals such as residual profit allocation by income or the destination-based cash flow tax.

By Sebastian Dueñas

Sebastian Dueñas examines controlled foreign corporation tax regimes in Japan, France, Germany, the United Kingdom, Colombia, the Netherlands, China, and Spain, regarding the possible expansion of existing anti-base-erosion CFC regimes or the potential adoption of a minimum tax.

By Teri Sprackland

Allowing tech giants to avoid taxationwhere they make money is a "crazy" system that provides for a "constant tax haven," French President Emmanuel Macron said.

By Isabel Gottlieb

Tech companies said they face steep challenges to collect the data they'll need to pay France's new digital taxÔøΩwhich could strengthen the U.S.'s trade case against it.

By Stephanie Soong Johnston

OECD-ledwork on taxing the digital economy may radically change the Irish business regime, so Ireland should focus on its nontax attractiveness to remain competitive once those changes are in place, a business group said.

By Annagabriella Colon

Representatives of major U.S. tech companies and others testifying at a hearing on France's digital services tax alleged that the tax is discriminatory and creates uncertainty for taxpayers.

By Tax Analyst

New Jersey has announced that itwill revise its controversial method for apportioning global intangible low-taxed income and foreign-derived intangible income.

By Tax Analyst

Two retired CPAs have commented on proposed regulations (REG-130700-14) on cloud transactions and digital content, suggesting changes to some examples to reflect industry practice, an additional example to reflect profit-shifting structures, and the retention of an example regarding an application service provider.

By Andrew Velarde

A bipartisan group of four members of Congress is asking Treasury to expand the exclusion from the base erosion and antiabuse tax for captive finance companies.

By Tax Analyst

The International Air Transport Association issued an analysis of Switzerland's proposal for an aviation carbon tax, outlining concernswith controlling emissions through taxation and the affect an emission increasewould have on Swiss families using air transportation.

By Tatiana Falcão

Tatiana Falcão examines the status of the OECD'swork program on the digitalization of the economy and considerswhat a consensus solution might look like.

French President Emmanuel Macron is pressing aheadwith a digital tax in France, a move U.S. President Donald Trump described as "foolishness", and the French leader is keen to reach an international agreement on taxing big tech companies. Late onwednesday, Macron urged the Trump administration to help reform global corporate taxes.

As a small open economy, Ireland may be affected significantly by the OECD's proposals to modify how taxing rights are allocated among countries, Irish business association Ibec has said. The OECD is developing new digital tax rules thatwould be presented for adoption internationally at the end of 2020,whichwill focus on two central pillars.

The Cayman Government has set out how companies should complywith new economic substance requirements,which must be met for certain companies to access the territory's tax regime. Under new requirements dictated in large part by the EU, companies that are tax resident in a low or no tax jurisdiction, and are engaged in key activities identified by the EU, must demonstrate that they meet minimum substance requirements as part of their annual tax return to access the territories' tax regimes.

The Brazilian tax system is globally known for its enormous complexity. Not only is the tax burden very high, but there are five different indirect taxes: ICMS, ISS, IPI, PIS and COFINS. This leads to innumerous ancillary obligations not to mention conflicts of jurisdiction between the federal government, states and municipalities on the tax levied on a great number of activities.

By Ryan Finley

The Ninth Circuit affirmed the Tax Court's 2017 decision in favor of Amazon, holding that the transfer pricing regulations' definition of the term "intangible property" excludes goodwill, going concern value, and other residual business assets.

By Martin A. Sullivan

In economic analysis, Martin A. Sullivan examines the overall tax effect of a U.S. multinational shifting profit among its controlled foreign corporations and finds that, due to a quirk in the basic architecture of the Tax Cuts and Jobs Act rules, moving income from the high-tax jurisdiction to the low-tax jurisdiction is not always a tax minimizing strategy and may in fact backfire.

By Mindy Herzfeld

In the third in a series on guidance addressing the Tax Cuts and Jobs Act, Mindy Herzfeld examines possible themes in that guidance.

Bywei Zhuang

In this article, the author discusses the major regulations to implement the base erosion and profit-shifting project in China and analyzes the impact on tax administration and tax compliance. She also provides an outlook on China's tax administration in combating BEPS.

By Francois Chadwick

In this article, the author proposes a multilateral solution to the tax challenges of the digital economy.

Mr. Trump's tax cuts unquestionably stimulated the American economy in 2018, helping to push economic growth to 2.5 percent for the year and fueling an increase in manufacturing jobs. But statistics from the government and other sources do not support Mr. Trump's claim about his policies' effectiveness in drawing investment and jobs from abroad.

Sen. Elizabethwarren, a Democratic presidential contender,wants to use U.S. trade agreements as leverage to ensure compliancewith international standards on preventing tax avoidance ÔøΩ an approach that could make both trade and tax negotiations much more complicated.