Int'l Tax News

Australia launched a consultation Jan. 23 on how itwill track underreported tax among users of sharing economy platforms like Uber Technologies Inc. and Airbnb Inc.

The EU must insist that the U.K. force its overseas territories and crown dependencies to adopt transparency rules that require companies to disclose their owners as part of any future post-Brexit trade relationship.

European Union presidency holder Romaniawill try Jan. 24 to jump start pending legislation to require multinational companies to make public their tax and profit reports,which they currently prepare for jurisdictions inwhich they have operations.

Corporate debt could now get more expensive under the 2017 overhaul, particularly for oil and gas refiners. The law capped the amount of interest payments companies canwrite off their tax bills. For many oil and gas refiners, aswell as manufacturers and retailers, their ceiling could be much lower than expected and more of them could become subject to the limit several years earlier than expected.

Petroleo Brasileiro SA (Petrobras) has received an unfavourable ruling from a tax court in a 1.7 billion reais (344.85 million pounds) dispute involving corporate tax charged in 2012 on overseas companies it controlled, the Brazilian state-run oil company said in a securities filing onwednesday.

In this paper, authors offer a pragmatic and contextualised analysis of the new "value creation" paradigm, and on this basis, authors examine its implications for international tax policy in the era of digitalisation. A special focus is put on the role of users (especially of online platforms) that are said to contribute to value creation e.g. by forming valuable networks, by providing data or by posting online content.

PwC summarizeshighlightsof the final 'toll tax' regulations under Section 965 released on January 15. The Final Regulations provide guidance relating to the 'toll tax' due upon the mandatory deemed repatriation of certain deferred foreign earnings.

Bankswill be examining the February 10k filings of their competitors to see how they are dealingwith the BEAT and GILTI provisions in the US TCJA.

The Court of Justice of the European Unionwill consider a French case (C-672/18) onwhether the EU merger directive (2009/133/EC) precludes the use of different assessment bases and rate rules to tax capital gains from the transfer of securities received in exchange during a merger and deferred capital gain.

In this article, the authors discuss recent U.S. international tax developments, including new regulations dealingwith foreign tax credits and interest expense deductions for companies.

The proposal for a digital services taxwill be reconsidered during the Romanian presidency of the EU Council, Finance Minister Eugen Teodorovici told lawmakers.

Data suggest that tax competition among EU countries has allowed multinationals to pay tax at rateswell below the statutory corporate rate,which in some member states is more than double the effective tax rate (ETR).

An OECD advisory committee has taken aim at unilateral actions and underscored the impossibility of ring-fencing the digital economy in a paper containing 11 recommendations for international tax measures in the digital age.

Spain's government has asked parliament to approve a digital services tax and a tax on financial transactions that it saidwill generate over ÔøΩ2 billion in revenue annually.

The treatment of interim distributions of non-section-965-related previously taxed earnings and profits (PTEP) that do not benefit from a gain reduction rule appears at oddswith the PTEP regime, according to practitioners.

The two markets of Hong Kong and Singapore are often comparedwith each other, however,where their transfer pricing regimes are concerned there are differences. Singapore and Hong Kong have reached significant milestones in their transfer pricing regimes.what are the differences between their regimes?

Over a dozen environmental groups, Indigenous representatives, and health advocateswill have their say in court this April in support of Canada's carbon tax. Ontario Court of Appeal Justice James MacPherson granted the groups standing Jan. 15 to participate in the case thatwill consider the constitutionality of the federal Greenhouse Gas Pollution Pricing Act.

Chile's government and opposition lawmakers are negotiating terms of the government's tax proposalwith the aim of reaching a deal by March, Finance Minister Felipe Larrain said.

The U.S. tax overhaul's boost to corporate profits could start to diminish soon as the effects of new international taxes and restrictions on interest deductions take hold, according to a research note from Morgan Stanley.

On Jan. 1, 2018, the biggest, most sweeping U.S. corporate tax cut ever enactedwent into effect. A year later,we're able to see how businesses used all that extra cash. The short answer: to buy back shares. The long answer is slightly more nuanced, but not by much.

The Internal Revenue Service released final rules on the one-time tax multinationals must pay on accumulated overseas earnings and profits.

Today, Treasury released final regulations under amended Section 965 ('the toll charge') and submitted them for publication in the Federal Register. PwC summerizes the final 965 regulations that provide guidance relating to the toll charge due upon the mandatory deemed repatriation of certain deferred foreign earnings.

Major stakeholders engulfed in Puerto Rico's bankruptcy-like proceedings urged a federal judge onwednesday to approve awatershed settlement designed to restructure nearly $18 billion in debt carried by the Puerto Rico Sales Tax Corp., or COFINA, saying it is the bestway to avert years of protracted litigation.

This could get awkward. Former Obama economic adviserswho claimed tax reformwouldn'twork have been miserable enoughwatching U.S. growth defy their predictions. Now they may have towatch other countries repeat the U.S. success as governments overseas consider lowering their corporate income tax rates.

An all-star roster of former Federal Reserve leaders andwhite House economic advisers are signing on to a new statement in support of a carbon tax on businesses that sends the revenue to U.S. citizens.

The stock market's reaction to Goldman Sachs Group Inc.'s fourth-quarter 2018 and year-end earnings reportswas unusually positive, thanks in part to a significant, and arguably obscured, tax benefit.

Opponents of Swiss tax reform legislation say they have gathered enough signatures to require a nationwide referendum on the law,whichwas enacted after EU complaints that the country's cantonal tax regime favors multinational companies.

Sweden's Parliament voted in Prime Minister Stefan Löfven for a second term after he secured a tenuous coalition minority government agreement involving tax cuts, ending months of uncertainty in thewake of an ambiguous election.

Complex contract negotiationswith customers undertaken by an Indian subsidiary of General Electric are sufficient to create a dependent-agent permanent establishment and taxable presence for other group subsidiaries resident in the United States.

The U.S. Tax Court's decision in Coca-Cola's ongoing transfer pricing disputewill provide taxpayerswith guidance regarding the level of reliance they can place on past closing agreementswhen determining future transfer pricing approaches.

The plethora of examples included in the proposed hybrid regs provides a dose ofwelcome certainty for practitioners, but the proposed regs' complexitywill require extensive knowledge of company structures.

This article,which focuses on a few questions that have arisen over the global intangible low-taxed income regime, highlights the challenges taxpayers and the governmentwill continue to face in attempting to make sense of the complex, confusing, and often internally inconsistent changes the TCJA made to international tax rules.

The TCJA tax on GILTI is simultaneously a minimum tax and a separate foreign tax credit basket (section 951A). GILTI,which is a residual, presumes that extranormal foreign profits are attributable to intangibles. GILTI claws back this extra income using a subpart F mechanism, but it is technically not a subpart F inclusion. GILTI is not limited by earnings and profits.

Eric Solomon of the American Bar Association Section of Taxation has submitted comments on proposed regulations (REG-104390-18) implementing provisions of the Tax Cuts and Jobs Act that require U.S. shareholders to include global intangible low-taxed income generated by controlled foreign corporations in their gross income. The TCJA added section 951A,which requires a U.S. shareholder of any CFC to include their GILTI in their gross income. The proposed regs provide guidance on determining the GILTI inclusion amount.

A law published recently in Panama's official gazette has extended the scope of the preferential tax regime under the Panama-Pacifico special economic zone to office administration services.

A decree that took effect January 8 in Peru lists the types of entities that are subject to the ultimate beneficial ownership tax regime.

The OECD's base erosion and profit-shifting project has failed to address some of the problems that gave rise to the project, and doesn't amount to real international tax reform, according to a nongovernmental organization.

Replacing a corporate income taxwith a destination-based cash flow tax (DBCFT)would yield significant macroeconomic benefits for the country making the switch and its trading partners, especially if other countries do so aswell.

New York Democratic Gov. Andrew Cuomo's recently released fiscal 2020 budget proposes to codify the state tax department's recent guidance on global intangible low-taxed income.

Customs authorities may demand disclosure of tax information related to select individuals associatedwith a company seeking status as an authorized economic operator, according to the EU's highest court.

Denmark's Tax Agency said it has been authorized to obtain tax information from three domestic cryptocurrency exchanges and has already accessed data on Danish taxpayerswho have used a Finnish bitcoin exchange.

A majority of EU countries saidwednesday that protections granted towhistleblowers, includingwhen it comes to fiscal matters, should be covered by just one piece of legislation, two EU officials told POLITICO.

Estonia's Bill on Amendments to the Income Tax Act entered into force January 1, implementing Council Directive (EU) 2016/1164 (the antiavoidance directive).

Global intangible low-taxed incomewould be excluded from Virginia's tax base under a recently introduced state Senate bill.

Indonesia's government has issued regulations requiring small to medium-size online businesses to pay tax at a rate of 0.5 percent of sales,while larger e-commerce companies must pay corporate income tax at a 25 percent rate.

As the OECDworks on long-term solutions for taxing the digital economy, the Swiss government has published its positions on how to proceed, stressing the importance of innovation and sustainable competitionwhile safeguarding tax receipts.

Although rates have fallen over the past two decades, corporate tax remains a key revenue source for government coffers, especially in developing countries, the OECD said in a new report.

Some practitioners may need to brush up on their knowledge of company structures following the release of exceptionally extensive proposed hybrid regs.

Final transition tax regs offer some modifications to a few hot-button issues, but the relief sought by taxpayerswho had lobbed a multitude of critiques at the proposed regs is limited in many circumstances.

EU Tax Commissioner Pierre Moscovici sought to convince member states to cede their right to veto tax measures in the EU Council by invoking annual VAT losses of ÔøΩ50 billion.