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Coca-Colas U.S. Transfer Pricing Dispute May Cost $12 Billion

  • By Ryan Finley

If the IRS applies the transfer pricing method approved by the Tax Court to the Coca-Cola Co.'s post-2009 tax years, the total liability in its U.S. transfer pricing dispute could reach $12 billion.

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It's VAT Talk Time Again


Jasper L. "Jack" Cummings, Jr., is of counselwith Alston & Bird LLP in Raleigh, North Carolina.

In this article, Cummings argues that the Biden administration has no reason to consider a VAT, at first, but because of Republican debt concerns and Democratic (and Republican) spending desires, it might be time to review the stakes and a bipartisan, credit-invoice VAT might some day appear.

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A Major Simplification of the OECD's Pillar 1 Proposal

  • By Michael J. Graetz

In this article, the author suggests major modifications to the OECD's pillar 1 blueprint proposal to create a new taxing right for multinational digital income and some product sales thatwould greatly simplify the proposal. The modifications rely on readily available existing financial information andwould achieve certainty in the application of pillar 1,while adhering to its fundamental structure and policies.

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Amazons U.S. Tax Costs Jumped in 2020. It Likely Would Pay Even More Under Biden Plan.

  • By Richard Rubin

WASHINGTONÔøΩ Amazon.com Inc., the company frequently cited by Democrats in their calls to raise corporate taxes, saw its tax liability jump last year as it prospered during the pandemic. But the technology giant, and others like it, could face even higher tax bills under the Biden administration's plan for a minimum tax rate on profitable corporations.

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Congress Signals Multinational Tax Perks on Chopping Block (1)

  • By Siri Bulusu and Kaustuv Basu

A proposal to eliminate a tax benefit for multinationals to help pay for a Covid stimulus package may be a sign that Congress is ready to target other such benefits. Congresswants to revoke the tax breakÔøΩwhich came into effect this year after first being introduced in 2004ÔøΩto help pay for a $1.9 trillion stimulus package (H. R. 133) aimed at additional Covid relief.without the benefit, multinationalswould lose an election that shields them from losing foreign tax credits if they have debt in the U.S.

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WEEKEND INSIGHTS: OECD Amount B and Marylands Digital Tax Bill

  • By Erin McManus

This is aweekend roundup of Bloomberg Tax Insights,written by practitioners and featuring expert analysis on current issues in tax practice and policy. The articles featured here represent just a handful of the many Insights published eachweek. For a full archive of articles, browse by jurisdiction at Daily Tax Report, Daily Tax Report: State, Daily Tax Report: International, Transfer Pricing Report, and Financial Accounting.

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Digital Tax Deal Critical in 2021, Indonesia Minister Says

  • By Isabel Gottlieb

Indonesia hopes for a global digital tax deal this year so the nation can lead a multilateral implementation starting next year, the country's finance minister said. "The expectation, and the hope, is that in 2021, under the Italian G20 Presidency,we are going to achieve a historic agreement on international taxation, essentially via the two-pillar solution under discussion," Sri Mulyani Indrawatiwrote in a Feb. 8 post on the Organization for Economic Cooperation and Development'swebsite. In pandemic-stricken economies, "Finding a sustainable, equitable, and fair source of revenue is critical," she said.

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Sunak agrees to tie own hands and stick with Tory triple tax lock


Chancellor Rishi Sunak has agreed to tie his own hands at next month's Budget by stickingwith the Conservatives' "triple tax lock",which stops him raising the rates of income tax, national insurance or value added tax. Treasury officials had hoped Mr Sunakwould ditch the Tories' 2019 election manifesto commitment,which stops him using the three biggest tax levers to start curbing a deficit that is expected to top £400bn in 2020-21 because of the coronavirus crisis.

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The BEPS Gambit: Will the OECD Know When to Resign?

  • By Robert Goulder

Robert Goulder examines recent proposals to simplify the OECD's pillar 1 blueprint and concludes the projectwill neverwin U.S. support.

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Resetting Expectations for a Digital Deal Under the Biden Administration

  • By Mindy Herzfeld

Mindy Herzfeld considers U.S. legislative obstacles facing any multilateral digital taxation deal agreed to by the Biden administration and reviews other considerations that could affect the chances of reaching global agreement.

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The Baby and the Bathwater: Reflections on the TCJA's International Provisions

  • By Reuven S. Avi-Yonah

Avi-Yonahwrites thatwith a new administration, it might be a good time to reflect on the Tax Cuts and Jobs Act, consideringwhat it should keep andwhat should it discard. He concludes thatthe TCJA's international provisions represent the best parts of the Act and should generally be kept (albeitwith important modifications) but that the FDII regime is a misguided export subsidy that should be discarded.

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Congressional Democrats Focused on Fixing Flaws in TCJA (1)

  • By Ryan Finley

Advisers to the Senate Finance and Houseways and Means committees believe there is broad support among congressional Democrats for legislative proposals thatwould address the Tax Cuts and Jobs Act's design flaws.

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Wyden Silent on Corporate Tax Rate

  • By Jad Chamseddine

Senate Finance Committee Chair Ronwyden, D-Ore., reiterated Democrats' desire to raise taxes on corporations but did not disclosewhether a consensus exists among his caucus on a specific rate.

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Multinationals Awaiting Final TCJA Rules Fret Bidens Proposals

  • By Emily L. Foster

Final guidance regarding foreign tax credits and the global intangible low-taxed income regime is atop the priority list for tax executives of multinational corporations, amid concerns about the new administration's tax policies.

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Digital tax: Feeling pretty good

  • By Bernie Becker

It's pretty striking ÔøΩ top finance officials in Europe are sounding extremely confident about getting a digital tax deal done this year, at least publicly.

Here's just one example: "It is highly likely thatwewill get the successwe areworking for so hard," Finance Minister Olaf Scholz of Germany told CNBC lastweek, as the latest round of talks being held through the Organization for Economic Cooperation and Developmentwerewrapping up.

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African Countries Push for Changes to OECD-Led Digital Tax Plan

  • By Isabel Gottlieb and Hamza Ali

The OECD's digital tax plan should set thresholds at a level to ensure African countries benefit from a reallocation of profits, a representative of the African Union saidwednesday. The OECD is trying to broker an agreement this year between 138 jurisdictions on overhauling the global tax system to address concerns about how multinationalsÔøΩespecially tech giantsÔøΩare taxed. The planwould include reallocating multinationals' profits and establishing a global minimum tax.

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India Budget Proposes Bigger Tax Hit on Digital Companies

  • By Siri Bulusu

Indiawants to expand the scope of a tax aimed at e-commerce companies doing business in the country. Expanding the equalization levy, as proposed Monday in India's 2021-22 budget,would hit a broader array of transactionswhere a nonresident company sells a good or service to a person in India through an online platform.

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Companies Push for Help in OECD-Led Effort to Revamp Tax Fights

  • By Isabel Gottlieb

As fights between multinationals and tax authorities continue to rise, companies hope making the dispute resolution process smoother and fasterwill give them more certainty.

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EU Calls $15.8 Billion Apple Tax Ruling Contradictory (2)

  • By Aoife White

The European Union is seeking to overturn Apple Inc.'s victory in a 13 billion-euro ($15.8 billion) tax dispute, saying judges used "contradictory reasoning"when they found that the company's Irish unitsweren't liable for huge payments.

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Its a Complex World for Troubled CFCs Tax Attributes

  • By Emily L. Foster

How the rules that limit the ability to use tax attributes following a loss corporation's ownership change apply to controlled foreign corporations is fraughtwith unanswered questions and in need of quick guidance.

Before the Tax Cuts and Jobs Act, applying section 382 rules to CFCswasn't really on practitioners' radar, Sara B. Zablotney of Kirkland & Ellis LLP said January 19 during a New York State Bar Association Tax Section virtual meeting.

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Stakeholders Push for Angel List in OECD Minimum Tax Plan

  • By Stephanie Soong Johnston and Ryan Finley

Oneway to simplify the OECD's overly complex global minimum tax plan and lighten administrative burdens is for tax administrations to identify low-risk jurisdictionswith appropriate tax bases and rates, businesses and tax advisers said.

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Amazon to Pass Along Cost of Spanish Digital Tax to Advertisers

  • By William Hoke

Amazon has advised businesses using its platform to sell products in Spain that itwill pass along the cost of the country's recently implemented 3 percent digital services tax.

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EU Opens Public Consultation on Design of Pending Digital Tax

  • By Annagabriella Colon

The European Commission has opened a public consultation seeking input on a proposed EU digital tax thatwouldwork in tandemwith the OECD initiative to reform international corporate taxation.

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EU Holding Off on Tax Reforms as It Awaits OECD Agreement

  • By Sarah Paez

The EUwants to address deficiencies in its tax haven blacklist and tax digital giants, but it mustwait for the outcome of OECD negotiations on global tax reform, a European Commission official said.

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Finance Ministers Hope for OECD Tax Reform Progress With Yellen

  • By Stephanie Soong Johnston

Finance ministers and otherswelcomed Janet Yellen's confirmation as Treasury secretary,with some expressing renewed hope for an agreement on global tax reform proposals through the OECD framework by the summer.

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Global policymakers look for Biden reset on trade, tax and climate

  • By FT reporters

Joe Biden's inauguration as president marks a crucial moment in international diplomacy: his predecessor's aggressive stance towards multilateral organisations and "America first" policies left many global debates in limbo. Expectations among economists and policymakers around theworld are running high that a reset in US attitudes towards international co-operation on trade, taxation, aid and the environmentwill soon emerge.

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What May We Expect of a Theory of International Tax Justice?

  • By Dirk Broekhuijsen and Henk Vording

In this article, authors discusswhat may be expected of a theory of international tax justice. After looking at the most important distributive aswell as procedural theories of tax justice, authors conclude that none of the existing theories can provide a coherent account of international tax justice. They therefore propose an alternative, more pragmatic approach drawing on Amartya Sen. Even if they do not agree on any particular notion of tax justice, it is still obvious that developing countries' interestswill be served by much simpler rules of international tax law.

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Is a global internet tax coming in 2021?

  • By Roger J. Cochetti

The subject of taxing the internet ÔøΩ and everything that goes on over the internet ÔøΩ has been a hot issue virtually since the "network of networks" morphed from the NSF Net to the internet in the 1990's.

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Will Tax Havens Fall Prey to Global Momentum on Anti-Abuse Tax Initiatives?

  • By Anshu Khanna

In thewake of the global financial crisis of 2007-2008, tax havens became a controversial topic as political leaders zeroed in on low-tax jurisdictions as a source of fiscal instability that aggravated the crisis.

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OECD Countries Prep for Plan B in Case Digital Tax Talks Fail

  • By Hamza Ali

The OECD is trying to get nearly 140 countries to agree to an overhaul of global tax by mid-2021. If that effort fails, a growing number of countries are preparing to launch unilateral measures aimed at tech giants like Facebook Inc. and Amazon.com Inc.

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Digital Tax Plans in U.K., Austria, Spain Unmoved by U.S. Rebuff (1)

  • By Joe Stanley-Smith and Sam Edwards

Austria, Spain, and the U.K.will not shelve their digital tax rollouts in response to U.S. assertions that they are discriminatory. The U.S. said Thursday itwill add the trio to a list of countries it says are discriminating against American companies by taxing the local revenue of internet giants like Google and Amazon. Spain's digital tax begins on Saturday,while the U.K. and Austrian taxes are already in effect.

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EU Preps to Tax Big Tech; Expands Call for Digital Tax Feedback

  • By Stephen Gardner

The European Union is seeking stakeholder input on how a digital tax might be introduced in the bloc. The European Commission, the EU's executive, announced Tuesday that itwould accept comments through April 12 to a questionnaire on issues including the minimum revenue thresholds abovewhich a digital levywould apply, specific digital activities that might be taxedÔøΩsuch as platforms' sale of user dataÔøΩand how taxable revenue can be delimited geographically. For example, should the proposal use the IP addresses of digital service users.

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U.S. Threat of Digital Tax Retaliation Unjustified: EU Official

  • By Stephen Gardner

U.S. President-elect Joe Biden should drop threatened countermeasures against European Union taxes on mainly American digital platforms, one of the bloc's top finance officials said Tuesday.

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An Argument for Eliminating Subpart F Income

  • By Anonymous

To the Editor:

In a recent article, Martin A. Sullivan criticizes the complexity of the Biden campaign's tax agenda and makes a persuasive case for pursuing the same goals by simpler means (Sullivan, "Biden's Incoherent Corporate Tax Policy," Tax Notes Federal, Jan. 4, 2021, p. 9).while President-elect Biden's campaign proposals have been heavily dissected since he secured the Democratic party nomination, and even more so since hewon the presidency, Sullivan's focus on simplicity is awelcome addition to the discourse.what Sullivan did not discuss, however, is the fact that the Biden campaign's proposals for global intangible low-taxed incomewould meaningfully simplify current law. Moreover, under one of Sullivan's own recommendations, an even greater simplification of our international tax system is easilywithin reach.

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EU Assessing Impact Digital Tax Would Have on SMEs, Consumers

  • By Sarah Paez

The European Commission has released information about the potential scope and impact of a digital levy thatwill be pursued if OECD countries fail to reach an agreement on new international tax rules by June.

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U.S. Must Rethink Stance on Global Tax Reform Deal, Harter Says

  • By Kiarra M. Strocko

A little-publicized German proposal floated in 2020 may be the key for the Biden administration to open the door to a global tax reform deal in 2021, Treasury's former top international tax policy negotiator said.

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U.S. Slams Digital Taxes of Austria, Spain, and U.K. as Unfair

  • By Amanda Athanasiou

The Office of the U.S. Trade Representative (USTR) has found that the digital taxes of Austria, Spain, and the United Kingdom discriminate against U.S. businesses, but has again held off on announcing retaliatory trade actions.

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First TCJA Suit Filed Against a State Taxing Repatriated Income

  • By Amy Hamilton

The Council On State Taxation has filed the nation's first lawsuit challenging a state's treatment of a Tax Cuts and Jobs Act provision.
At issue in Council On State Taxation v. Nebraska Department of Revenue, pending in the District Court of Lancaster County, Nebraska, is the Department of Revenue's disallowance of any state deduction claimed for section 965 deemed repatriations.

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Stakeholders Push for Angel List in OECD Minimum Tax Plan (1)

  • By Stephanie Soong Johnston
  • By Ryan Finley

Oneway to simplify the OECD's overly complex global minimum tax plan and lighten administrative burdens is for tax administrations to identify low-risk jurisdictionswith appropriate tax bases and rates, businesses and tax advisers said.

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Germany seeks global corporate tax deal with Biden administration

  • By Guy Chazan

German finance minister Olaf Scholz has said hewill seek a dealwith the incoming Biden administration on global rules for corporate taxation, as hopes rise in Berlin that the end of the Trump presidencywill usher in a new era of multilateral co-operation.

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US says digital taxes in Spain, Austria and UK are discriminatory

  • By Aime Williams

The US has said that digital taxes in Spain, Austria and the UK are discriminating against American tech companies, paving theway for tariffs and setting the scene for transatlantic trade conflict as the Biden administration takes power.

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The 283 Days of Stock Returns after the 2016 Election


Conventionalwisdom suggests that the promise of tax legislation played an important and positive role in the 25% increase in the stock market that began on November 9, 2016 and continued through December 22, 2017 (the day TCJAwas signed into law). Our comprehensive and exhaustive forensic analysis confirms its positive effect.with that said,we find that its net impact is relatively modest. To come to this conclusion,we first construct a novel daily human-based attribution by carefully reading the news on each of the 283 days. This exercise shows the 52 days inwhich tax-related newswas important make up less than 1% of the total observed return.we attribute large gains to tax-related news immediately after the election aswell as the build-up to passage in late 2017.

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Biden Tax-Increase Agenda Revived as Democrats Win Senate

  • By Richard Rubin

Democratic control of the Senate gives President-elect Joe Biden a much stronger chance of raising taxes on corporations and high-income households. Until thisweek's Georgia runoff elections, Mr. Biden's plans for tax increaseswere running into solid opposition from the Republican-controlled Senate. But now, Democratswill hold thewhite House, Senate and House simultaneously for the first time in more than a decade, and they are poised to use that power.

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France Seeks De-Escalation from Biden on Trade, Minister Says

  • By Phil Serafino

France is open to all signs of "de-escalation" from incoming Biden administration in U.S. on trade disputes over aircraft makers and a digital tax, French Trade Minister Franck Riester says in interview on BFM Business television.

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Why the World is Watching


The digital economy is equivalent to 15.5% of global GDP and is growing two and a half times faster than global GDP over the past 15 years, according to theworld Bank. This rapid expansion has sparked global debates in many legal and regulatory realms. In the field of international taxation, the debate focuses onwhether the current rules are appropriate in the modern global economy, especially regarding the allocation of income and profits among countries for tax purposes or purposes of being potentially subject to tax.

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OECD Opens Global Tax Meeting to Public for the First Time

  • By Stephanie Soong Johnston

In a bid to boost transparency in tax cooperation among nearly 140 countries, the OECDwill livestream the group's next meeting, given public interest in taxing digital activity and other issues amid the COVID-19 pandemic.

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A Look Ahead: Hurry Up and Wait for a Global Tax Reform Deal

  • By Stephanie Soong Johnston

Despite the OECD's best efforts to convince countries to sign off on proposals to tax the digital economy ÔøΩ during a pandemic, no less ÔøΩ a deal remains elusive, awaiting signals from the Biden administration in 2021.

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Stepping Forward, Back, and Sideways on Tax Transparency

  • By Mindy Herzfeld

With a split Senate, President-elect Joe Biden probablywon't be able to enact the kind of tax increases he campaigned on or use executive action to bring about the big fiscal policy changes progressiveswant. But there is one areawhere the incoming administrationwill have the chance to make a mark and help influence corporate and individual taxpayer activities.

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A Look Ahead: 2021 to Be Pivotal Year for EU Taxation

  • By Elodie Lamer

The European Commission's action plan for business taxation,which outlines its digital and green transition strategies,will be published soon, and Portugal ÔøΩwhich holds the EU presidency ÔøΩ has promised to push that agenda forward.

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Is GILTI Constitutional?

  • By Reuven S. Avi-Yonah

At first glance, the question in the headline may appear to be frivolous. The global intangible low-taxed income regime must be constitutional ÔøΩ GILTI builds on subpart F,which built on the foreign personal holding company (FPHC) regime thatwas declared to be constitutional in Eder back in1943. But perhaps it isn't that easy.

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