Int'l Tax News

The IRS's Large Business and International Division has announced three new compliance campaigns that focus on transfer pricing for captive service providers and tax and information reporting requirements concerning offshore activities.

Francewill push for the European Union to adopt a regulatory framework on cryptocurrencies similar to the one it brought in lastweek at a national level, becoming the first major country to do so, French Finance Minister Bruno Le Maire said on Monday.

Poland's Ministry of Finance has issued a draft bill on a simplified advance pricing agreement process thatwouldwaive deductibility restrictions on intragroup expenses.

The Dutch governmentwill begin a broad reassessment of its tax system thatwill examine the current tax mix and its distributive effects, taxation of income from digital sources, and the future of corporate taxation.

South Korea's finance minister said the planned tax cut for stock transactionswill begin on June 3, according to local media reports on Sunday.

Consumers' outlook on the U.S. economyworsened in April, as a survey suggested the impact of tax cuts has now run its course for American households. The University of Michigan said Friday its preliminary index of consumer sentimentwas 96.9 this month, down from March's final reading of 98.4. That undershot economists' expectations for a preliminary reading of 98.0.

The European Union's executive branch is proposing that individual member countries drop their right to veto decisions on energy taxes, a move that could facilitate the introduction of a carbon tax across thewhole bloc.

A new report, citing data from a left-leaning think tank, reveals that at least 60 companies avoided paying taxes this year as a result of the new tax law ÔøΩ a total that is about twice as many as previous years.

Tax Cuts and Jobs Act is a regressive response to the challenges posed by today's global economy. Not only do the vast majority of the tax benefits from the legislation accrue to those at the top of the income distribution, but the legislationweakens the health security of ordinary Americans. Reduced spending on health insurance subsidies for poor Americanswill increase the number of uninsured Americans and generate more expensive premiums for those that remain insured.

A top candidate for the European Commission presidency said Thursday he supports a Europewide minimum corporate tax because European Union countries are no longer powerful enough to extract a fair amount of revenue from the largest companies on their own.

Democratic presidential candidate Elizabethwarren is proposing a new 7% tax on the largest, most profitable U.S. companies, a move thatwould increase corporate tax collections by about 30% over the next decade.

German Finance Minister Olaf Scholz told Reuters in an interview onwednesday hewould urge financial leaders during meetings inwashington later thisweek to aim for a minimum level of corporate taxation globally.

The 2017 tax law looks appealing to many citizens because it handed out a lot of money thatwould otherwise have gone to the Treasury. However, the oversized budget deficits, caused in part by the unavoidable aging of our population,will force lawmakers to revisit that tax law. The American people should be prepared for another very different dose of tax reform.

Investors are using multinational companies' tax disclosures, such as country-by-country reports, to inform their investment decisions - andwant consistent disclosure formats to make comparisons easier.

For years the advent of the digital economy has left countries stumped in their attempt to tax income earned by foreign firmswithout physical presencewithin their jurisdiction. International organizations and their member countries have failed in their attempts to tweak the rules of the international tax regime and address these challenges presented by the digital economy. This article argues that such conservative approach could notwork, and fundamental reform is inevitable.

The Austrian Government announced on April 3, 2019, a package of tax measures aimed at the digital economy, including a five percent tax on revenue derived from the sale of digital advertising services and the removal of the low-value VAT exemption threshold.

The Australian Taxation Office has opened a consultation on a draft Law Companion Ruling on the targeted integrity rule thatwill apply under the new hybrid mismatch regime.

Vera Jourová, European Commissioner for Justice, Consumers, and Gender Equality, spoke about digitalization, data protection legislation, and challenges that the United States and European Union face regarding online data control in an April 11 speech at the Brookings Institute.

Deliberate misstatements on trade invoices have created a trillion-dollar gap in the actual value of goods, leading to about $200 billion in annual tax revenue losses, according to estimates by Global Financial Integrity (GFI).

Latin American countries' preferred proposal for addressing the tax challenges of the digital economy is driven by an eroding tax base, according to a tax specialistwith the Inter-American Development Bank (IADB).

A revamped money laundering blacklistwill be submitted to the EU Council in October, EU Justice Commissioner Věra Jourová told Tax Notes.

A modest reallocation of taxing rights that is palatable to countries losing some tax revenues could be key to addressing the challenge of generating OECD consensus on new global tax rules.

Mindy Herzfeld describes recent proposals to make corporate tax data more transparent, including those by the Financial Accounting Standards Board and the Global Reporting Initiative.

In news analysis, Carrie Brandon Elliot reviews how the new hybrid proposed regulations solve some, but not all, of thewell-known problems related to dual consolidated losses.

In news analysis, Lee A. Sheppard discusses emerging trends in tax collection in developing economies and how these are causing difficulties for traditional organizations like the OECD and IMF.

Canadian Finance Minister Bill Morneau reiterated that Canada is awaiting the OECD's report concerning digital taxation and noted the importance of the United States' position to Canada's future decisions.

A recent statement by Deputy Finance Minister Arturo Herrera that the Mexican government intends to tax digital services has prompted concerns that pending legislation might be used to implement the plan.

The U.N. has released a package of draft updates to its transfer pricing manual for developing countries, including a new chapter on financial transactions and revised profit-split guidance consistentwith recent OECD updates.

In an April 10 release, the chairs and ranking minority members of the Houseways and Means and Senate Finance committees expressed support for OECD negotiations on the digital economy and said digital service taxes, even on an interim basis, can have negative effects on U.S. businesses, the economy, and diplomacy.

H.R. 2210, the Invest in America Act, introduced by Houseways and Means Committee member John B. Larson, D-Conn.,would repeal provisions of the Foreign Investment in Real Property Tax Act of 1980 concerning capital gains taxation of U.S. investments by foreigners, in addition to repealing other provisions to stimulate foreign investment in the United States.

The EU Energy Union said it supports the European Commission's proposal to move away from unanimity to qualified majority voting (QMV) on energy taxation.

Countries shouldn't enact unilateral digital services taxes but should insteadworkwith the international community to find a solution, U.S. lawmakers urged in a statement.

Minnesota House lawmakers have introduced a bill thatwould include foreign corporations that generate global intangible low-taxed income in the corporate unitary group.

In this article, the author discusses the process and rationale behind the EU's anti-money laundering blacklist and the U.S. Treasury's response.

In this article, the author examines OECD and U.S. approaches to counteract treaty shopping and abuse and provides a framework of topics that taxpayers might need to focus on to claim treaty benefits. He also explores the symbiotic relationship between U.S. tax treaty policy and the action plans released as part of the OECD's base erosion and profit-shifting project.

Germany's environment minister says the governmentwill discuss introducing a carbon tax as part of its national plan to curb climate change.

There is no gap in the architecture of globalization more serious than the failure of nations to prevent global companies andwealthy individuals from escaping taxation through tax havens, accounting devices and pressure to bring down business tax rates.

The Czech Republic has published corporate income tax amendments in connectionwith its implementation of the EU's anti-tax-avoidance directive (ATAD). Most of the new measures took effect April 1.

The European Commission rerouted an informal discussion on growth and taxation by the Economic and Financial Affairs Council April 6 to promote a shift toward qualified majority voting in tax matters. Three member states said they oppose the move.

The French public is exasperated over the country's high tax burden, so the government must respond quickly and decisively, France's prime minister said following the close of a national consultation initiated after violent protests.

The objective of the proposed Swiss corporate tax reform is to ensure that the Swiss corporate tax system is in linewith international minimal standards,which recognize as harmful the cantonal preferential tax regimes for holding, domicile and mixed companies. Accordingly, these privileged tax regimes need to be abolished by the cantons. The proposed new tax provisions are intended to achieve international acceptancewhile at the same time maintaining Switzerland's attraction for multinational enterprises.

The Treasury Department is being pressed by Republican lawmakers and business groups to correct a defect in a new tax on foreign earnings that has companies like biotech giant Amgen Inc. saying they may move their research and development operations offshore. They are asking Treasury to clarify how to properly allocate research and development expenses under the new rules,which are meant to ensure multinationals pay at least a minimum amount of tax on overseas profits earned in countrieswith lower tax rates than the U.S.

The treatment of stock payments under the new base erosion and anti-abuse tax is high on Treasury's list of outstanding items to tackle, an official said. The Treasury Department has received comments on pending issueswith the BEAT, includingwhether non-cash or property payments, including stock payments or the assumption of a liability, should be captured under the new tax.

Jeff VanderWolk of Squire Patton Boggs querieswhether the OECD needs to revise profit allocation rules to address digitalization.

Germany, Netherlands plan towork together to establish "minimum tax standard" to counter tax havens, according to joint statement supplied by Germany's Finance Ministry.

President Donald Trump's signature tax cuts are set to end starting 2021, and Corporate America must prepare for an increase in levies as it's unlikely Congresswill extend the stimulus, according to Morgan Stanley.