Int'l Tax News

An international agency monitoring tax transparency reported most of its member countries are complying with tax information exchange standards, but the availability of certain information can be improved.

An IRS official has confirmed that the agency still plans to release foreign tax credit guidance on pillar 2 by year-end and expects to extend temporary relief from final FTC rules at the same time.

A combination of government policies is finally succeeding in reversing a long decline in solar manufacturing in the United States.

The IRS plans to go ahead with guidance on how foreign tax credit regulations interact with the new global minimum tax even though it’s still considering whether and how those regulations might be modified, an IRS official said Monday.

Implementation of global minimum tax rules is happening, and there’s nothing the United States can do to stop it, members of the European Parliament subcommittee on tax matters told U.S. lawmakers.

Italy has introduced an innovative dispute prevention and resolution provision based on the principle of reciprocity as part of its pillar 2 implementation strategy, according to a finance ministry official.

A White House economist has responded to ExxonMobil’s support for a carbon tax by casting serious doubt on the possibility of achieving a global harmonized carbon market without any climate policy deviations.

Jamaica plans on establishing a qualified domestic minimum top-up tax as part of its implementation of the pending global minimum tax, a Jamaican official said Tuesday.

The US and Canada are headed toward a “big fight” over Canada’s plans to enact a digital services tax unless a solution is found, US Ambassador David Cohen said Tuesday.

Wally Adeyemo, the deputy Treasury secretary, said the United States was continuing to look for ways to improve coordination with Europe on climate and energy security initiatives.

The United States considers the treatment of the nonrefundable research credit by the pillar 2 global minimum tax regime an important priority as countries begin to implement the legislation, a Treasury official said.

Argentina will be ready to present a proposal for a withholding tax mechanism on digital service providers if progress isn’t made soon on the signing of a multilateral convention implementing pillar 1, an Argentine official said.

Oliver Treidler explains the structure of the OECD’s amount B and reviews its discussion draft comments and suggestions submitted by many industry participants.

A draft treaty that would implement a key part of the OECD’s global tax agreement represents “significant progress,” but work remains to be done, a Treasury Department official said Monday.

The pricing of intangibles in related-party transactions will cause unsolvable disputes unless the OECD provides revised guidance, according to panelists at the annual Congress of the International Fiscal Association in Cancun, Mexico.

If Bulgaria doesn’t join other EU member states in including a substance-based carveout in its proposed domestic minimum top-up tax, it will damage its ability to attract foreign investment, a trade group warned.

A senior Treasury official is offering greater detail on what public input the department is seeking in response to the amount A multilateral convention under pillar 1, including comments on what the draft document got wrong.

During a debate at the EU’s annual tax symposium about the advantages of the OECD's global tax reform plan versus a U.N. tax convention, the OECD said developing countries helped to shape its tax pillars.

Global minimum tax rules and a common EU corporate tax system will likely overload companies’ capacity for compliance because the interplay between the regimes could be overly complex, a business representative warned.

The Netherlands should consider other options in case countries can’t reach agreement soon on the amount A multilateral treaty under pillar 1 of the two-pillar global tax reform plan, a Dutch tax official told parliament.

The Court of Federal Claims has allowed a U.S. couple residing in France to use the France-U.S. tax treaty to claim a foreign tax credit against their net investment income tax liability.

Businesses large and small are being hit by a change in tax rules on R&D expenses. Some are struggling to stay afloat.

The inclusive framework on base erosion and profit shifting is considering issuing pillar 2 guidance on the treatment of deferred tax assets in jurisdictions with federal and subnational taxes, an OECD official said.

An initial projected revenue increase under pillar 2 global minimum tax rules has diminished because of negotiated concessions like a substance-based carveout and generous treatment of tax credits, according to a sweeping EU study.

Nongovernmental organizations have expressed disappointment regarding the EU’s hesitancy about joining a legally binding U.N. tax convention, but EU officials said they believe it would duplicate and could undermine the OECD’s work.

Disagreements between the global north and south and debates over whether the U.N. or OECD should lead on tax matters could cause a breakdown in multilateral tax cooperation, a Colombian government adviser warned.

Suranjali Tandon and Chetan Rao explain the potential importance of amount B for developing countries and suggest ways that amount B can be improved to address specific developing country needs.

Amplifying its efforts to go after tax dodgers, the IRS Friday announced new efforts to target foreign corporations and the largest corporate taxpayers.

In their compromise report on the role of tax policy in times of crisis, members of the European Parliament have called for a broader excess profits tax net and inflation-adjusted personal income tax brackets.

Five EU member states have told the European Commission that they plan to avail of the possibility to delay implementation of the pillar 2 directive, a top EU tax official said.

Senate and House tax-writers seeking to encourage cross-border business collaboration between Taiwan and the US released bipartisan bill text Thursday outlining their plan to provide treaty-like benefits through the tax code.

Ireland released a Treasury bill Thursday with details of its plans to roll out the global minimum tax, a part of the OECD-led global tax deal.

The United Nations is negotiating a draft resolution to establish a legally binding convention to promote inclusivity for developing countries in international tax cooperation.

The U.N. shouldn’t pursue further work on the potential effects of global minimum tax rules on tax incentives in the extractives industry because it would be inappropriate, several tax committee delegates said.

Canada’s proposed tax on big technology firms could raise as much as C$7.2 billion ($5.3 billion) over five fiscal years, according to a new projection from a parliamentary spending watchdog.

The Treasury Department is working on a potential “next push of guidance” on how the US will reconcile some issues relating to the new global minimum tax, a department official said Tuesday.

Nigeria filed a draft resolution calling for the United Nations to create an international tax convention, the next step toward the organization potentially assuming a greater role in global tax cooperation.

European Union finance ministers Tuesday approved an update to the bloc’s list of jurisdictions considered uncooperative on tax, adding three and removing three, leaving the list with 16 entries.

U.S. Treasury Secretary Janet Yellen indicated countries will work into 2024 to settle issues preventing the signing of the pillar 1 multilateral convention, which would mean a related digital tax freeze will soon expire.

Computations to reallocate taxing rights to markets under a global treaty might be simplified over time, according to one senior official from the OECD.

Treasury Secretary Janet Yellen indicated the US will be unable to sign a treaty on global tax rules in time to uphold a deal that prevents other countries from imposing new levies on some of the largest American tech companies.

Mindy Herzfeld explains that the OECD will likely find itself policing a wider range of state subsidies as countries look for creative ways to shore up investment while staying on the right side of pillar 2.

Representatives of more than 40 members of the Forum on Tax Administration have pledged to facilitate the administration of global minimum tax rules by cooperating on compliance issues like risk assessment.

Fadi Shaheen floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by the UTPR entity, and he addresses questions that would follow regarding the desirability of such a confiscatory tax and its interaction with tax treaties.

A variety of knotty issues remain over a multilateral treaty aimed at implementing a key part of the OECD’s global tax agreement—including disagreements among countries over withholding taxes and digital services taxes, and getting the US to sign on.

The OECD has published the text of a treaty providing for the reallocation of taxing rights to market jurisdictions and a digital tax repeal, but some details need resolution before countries can start signing it.

Among the many perplexing questions raised by the OECD’s two-pillar project on global tax policy, one mystery is why the government of Canada has broken ranks with other major players in the Inclusive Framework on Base Erosion and Profit Shifting—by announcing its intention to proceed unilaterally with a digital services tax.

U.S. Trade Representative Katherine Tai is facing increasing pressure from lawmakers to take decisive action against the impending enactment of Canada’s digital services tax as Senate Finance Committee members urge new warnings.