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Int'l Tax News

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Limits in US-Taiwan Tax Relief Bill Differ From a Typical Treaty

  • By Jeffrey Tebbs and Caroline Reaves

The United States-Taiwan Expedited Double-Tax Relief Act, which is advancing to the full Senate, would provide an array of tax benefits on certain income earned by qualified residents of Taiwan from US investments or activities.

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Global Rulemaker Changes SME Accounting to Avoid OECD Issues

  • By Michael Kapoor

The International Accounting Standards Board changed small company accounting rules Friday in order to simplify issues created by OECD global minimum tax rules.

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U.K. Updates Draft Pillar 2 Amendments With Safe Harbors

  • By Stephanie Soong

The United Kingdom has published more draft measures revising its pillar 2 legislation to reflect safe harbors and other features of the OECD’s latest administrative guidance for the global anti-base-erosion rules.

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French Finance Bill 2024 Moves to Adopt Global Minimum Tax Rules

  • By Stephanie Soong

The French government is moving to adopt the EU’s pillar 2 directive, implementing global anti-base-erosion rules and a domestic minimum top-up tax, according to its 2024 draft finance bill.

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Hungary Makes Moves Toward Global Minimum Tax Adoption

  • By Stephanie Soong

Hungary’s finance minister has started talks with large Hungarian companies about ensuring the country remains competitive as it prepares draft legislation in the fall for transposing the EU’s global minimum tax directive into domestic law.

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Italy Offers Banks Get-Out Clause on Divisive Windfall Tax

  • By Sonia Sirletti, Daniele Lepido, and Alessandra Migliaccio

The Italian government modified a controversial windfall tax on banks, giving lenders an option to avoid paying if they set aside additional capital reserves.

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Deputy U.S. Trade Rep Presses Canada on Digital Tax Plan

  • By Stephanie Soong

The Office of the U.S. Trade Representative has again pushed back against Canada’s plans to introduce a digital services tax, days after American lawmakers warned that the tax, if imposed, might damage Canada-U.S. trade relations.

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Global Carbon Pricing Challenge Gains New Members at U.N. Summit

  • By Amanda Athanasiou

Government officials from Norway and Denmark announced that their countries are joining the Canadian-led global carbon pricing challenge and emphasized the importance of international cooperation on carbon taxes to effectively reduce emissions.

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U.S. Issues Final Rules to Keep Chip Funds Out of China

  • By Ana Swanson

The Biden administration on September 22 issued final rules that would prohibit chip companies vying for a new infusion of federal cash from carrying out certain business expansions, partnerships and research in China, in what it described as an effort to protect United States national security.

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Plowgian to U.N.: Don't Torpedo Global Tax Deal

  • By Alexander Rifaat

A senior Treasury official has cautioned against efforts by the U.N. to pursue a separate multinational tax agreement, arguing that it would fundamentally undermine the progress made by the OECD’s inclusive framework.

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IRS Considers Extension on Rollback of Foreign Tax Credit Rules

  • By Danielle Muoio Dunn

The IRS is considering extending the period in which taxpayers can rely on old foreign tax credit rules, while the agency mulls changes to newer rules.

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World Leaders Call on UN to Start Developing Global Tax Norms

  • By Danish Mehboob

Several world leaders at a United Nations high-level panel said that the OECD is not the preferred organization to lead the international tax cooperation agenda, but existing work should not be duplicated.

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Gentiloni Warns Against the Search for Pillar 2 Loopholes

  • By Elodie Lamer

EU Tax Commissioner Paolo Gentiloni told members of the European Parliament that the EU will have to work hard to avoid a situation in which private actors or jurisdictions find loopholes in pillar 2 of the OECD's global tax plan.

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W&M Republicans Push for Pillar 2 Slowdown While Promoting GILTI

  • By Cady Stanton

House Republican taxwriters are hoping other countries will delay implementation of pillar 2 of the OECD global tax deal while they separately encourage leaders to implement versions of the United States’ global intangible low-taxed income regime.

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House Lawmakers Seek Pressure Against Canada’s Digital Tax Plans

  • By Chris Cioffi

A bipartisan group of House Ways and Means Committee members called on the Treasury, the US Trade Representative, and the Organization for Economic Cooperation and Development to push back on Canada’s decision to impose a digital services tax.

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Dutch Budget Offers Fix for Global Minimum Tax Shortfalls

  • By Danish Mehboob

The Dutch tax plan presented to Parliament on Tuesday highlighted ways to make up for uncertain tax revenues from the global minimum tax to start in 2024.

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Slow EU Pillar 2 Adoption Is a Challenge, Says EU Official

  • By Stephanie Soong

Although some EU member states have started transposing the EU’s global minimum tax directive into their domestic law, others aren’t acting as quickly, and time is running out, according to a European Commission official.

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The Biggest Casualty of Pillar 2's Bias for State Subsidies? The U.S.

  • By Stephen A. Bonovich

Stephen A. Bonovich considers the inexplicable and unexplained decision to design pillar 2 to attack various forms of tax rate competition but ignore state subsidies, even though tax academicians, officials, and practitioners have long concluded that such a design is highly irrational and gives rise to market distortions — the exact opposite of what pillar 2 seeks to achieve. He also looks at the practical implications of ignoring those views for the United States, the EU, and China.

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Global Minimum Levy Won’t Stop EU Tax Competition, Report Says

  • By Stephen Gardner

Introduction of the 15% global minimum tax will lead jurisdictions to seek new ways of offering tax breaks to attract companies, according to a report on launch of the tax in the European Union.

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Multinationals Report Large Tax Benefits From Transfers of IP to Switzerland

  • By Martin A. Sullivan

Martin A. Sullivan uses data from Form 10-K reports to illustrate some policy shortcomings of recent tax reform efforts, focusing on intellectual property transfers and Switzerland’s status as a tax haven.

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Ireland Opens Consultation on Tax Breaks for Dividend Income

  • By Danish Mehboob

Ireland is considering a plan to offer corporate tax breaks for dividend income and foreign branches.

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Caribbean Policy Cries for Change Following the Global Minimum Tax

  • By Bruce Zagaris

Bruce Zagaris breaks down the effect changes in global tax trends have had on Caribbean nations and examines measures to encourage growth in the region.

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Senate Committee Backs Bill to Deepen U.S. Economic Ties With Taiwan

  • By Alan Rappeport

The Senate Finance Committee on September 14 passed a bill that would deepen economic ties between the United States and Taiwan and effectively create a tax treaty that is expected to pave the way for more Taiwanese investment in the American semiconductor industry.

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It's Time for the United States to Move On From the DST Feud

  • By Ryan Finley

Ryan Finley asserts that the apparent failure of the United States’ global crusade against digital services taxes should prompt a reassessment of U.S. policy.

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Some Open Questions on the U.N. Tax Cooperation Effort

  • By Nana Ama Sarfo

Nana Ama Sarfo outlines some open questions generated by the U.N. secretary-general's recent report on international tax cooperation.

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US Backs Simpler Transfer Pricing Reform in Global Tax Deal

  • By James Munson

The US reiterated its preference Tuesday for what it says is an easier method for determining which transactions will be affected by new streamlined global transfer pricing rules.

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G-20 Leaders Call for Finalizing Pillar 1 Tax Treaty, Amount B

  • By Stephanie Soong

Countries should work quickly on pillar 1 of the OECD’s two-pillar tax reform plan, including unblocking progress on the amount A multilateral convention and completing amount B transfer pricing simplification rules, G-20 leaders said.

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U.S. Trade Group Pans Canada's DST for Undermining OECD Process

  • By Sarah Paez

Canada's digital services tax legislation could weaken the two-pillar plan to modernize corporate tax rules from the OECD/G-20 inclusive framework on base erosion and profit shifting, according to a U.S. trade group.

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G20 Leaders Call for Transfer Pricing, Crypto Fixes in Tax Deal

  • By Danish Mehboob

The Group of 20 leaders are calling for a resolution on remaining issues in the global tax deal, including tackling transfer pricing and crypto issues.

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Tech Groups Urge Canada to Drop DST and Refocus on OECD Tax Deal

  • By Stephanie Soong

The Canadian government should withdraw its plans for a digital services tax to avoid creating “perverse incentives” for countries to undermine a major OECD global tax reform agreement, tech companies said.

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European Commission Draws Lessons From Past Failures With BEFIT

  • By Elodie Lamer

The European Commission says it used “valuable insights gained from many years of negotiations” on corporate tax proposals — including those that failed — to design its much-awaited proposal for a common corporate tax framework.

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Fixing or Nixing GLOBE

  • By Sol Picciotto

Sol Picciotto explores the origins of the global anti-base-erosion tax, the main element of pillar 2, its current implementation, and the role the United States could play in supporting or opposing these international tax reforms.

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Global Minimum Tax to Reduce Low-Taxed Profit by 70%, OECD Says

  • By Lauren Vella

In a tax report delivered to the G20 Friday, the Organization for Economic Cooperation and Development said that the 15% global minimum tax is expected to rake in $200 billion annually, and that by 2025 more than 90% of multinational corporations making over 750 million euros ($803 million) will be subject to it.

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House Republicans Urge Germany to Repeal ‘Discriminatory’ IP Tax

  • By Samantha Handler

Nine House Republicans pressed the German Minister of Finance to repeal Germany’s century old tax on intellectual property income that’s recently troubled US companies.

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African Countries Seek to Craft Tax System for Whole Continent

  • By Lauren Vella

African countries are partnering with three donors to develop a digital tax system for the continent’s governments to own following years of costly, piecemeal updates to their tax administration tools.

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New Corporate Minimum Tax Ushers In Confusion and a Lobbying Blitz

  • By Alan Rappeport

The new corporate minimum tax has become a challenge for the Biden administration, which has faced intense lobbying from industries that could be on the hook for billions of dollars in new taxes. Those groups have been flooding the Treasury Department with letters asking for lenient interpretations of the law and trying to create new loopholes before their tax bills come due next year.

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BEFIT to Apply to Pillar 2 Groups, Align Transfer Pricing Rules

  • By Sarah Paez

A proposed EU common corporate tax system would apply to the same large multinational and domestic groups in scope of pillar 2 and harmonize transfer pricing rules across the bloc.

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Ireland Amends Patent Box in Response to Pillar 2 Rule

  • By Stephanie Soong

The Irish government has increased the effective tax rate of its knowledge development box, responding to the treaty-based subject-to-tax rule under pillar 2 of the OECD-brokered tax reform plan.

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Tax Pros Fear High Court Will Go Too Far in Transition-Tax Case

  • By Isabel Gottlieb and Michael Rapoport

Tax practitioners are getting increasingly anxious about a major foreign income tax case before the Supreme Court that they fear could tear down wide swaths of the tax code, as a deadline approaches for parties to weigh in. 

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Global Tax Deal and Taiwan Top Congress’ Fall Tax To-Do List

  • By Chris Cioffi and Samantha Handler

Congressional tax-writers start their trek back to Washington this week with plans to consider a Taiwan tax bill, scrutinize the global tax deal, and hash out funding for the IRS.

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Pillar 2 and IP Boxes: A New Chance to Scrap a Flawed Policy

  • By Ryan Finley

Ryan Finley explains why pillar 2 adoption should prompt a reassessment of patent boxes and other income-based tax incentives for intellectual property.

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Did FDII Raise Revenue for the U.S. Treasury?

  • By Martin A. Sullivan

Martin A. Sullivan considers whether the foreign-derived intangible income provisions of the Tax Cuts and Jobs Act did, in fact, raise revenue for the U.S. fisc.

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Technology Group Wants Amount B Extended to Digital Services

  • By Sarah Paez

The OECD/G-20 inclusive framework on base erosion and profit shifting should expand the scope of amount B of pillar 1 to include digital services, according to the Information Technology Industry Council.

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Moore Outcome Could Mean a Whole Lot Less Revenue

  • By Jonathan Curry

Observers have long warned that an expansive Supreme Court decision in Moore v. United States could have catastrophic repercussions for the tax code. Now, the Tax Foundation has put a price tag on it.

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Italian Tax Reform Law Enabling Pillar 2 Adoption Goes Live

  • By Stephanie Soong

Italy’s new law enabling the government to implement sweeping tax system reforms has taken effect, paving the way for the transposition of the EU’s global minimum tax directive.

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FASB Approves Expanded Tax Disclosure Requirements for Companies Despite Opposition

  • By Mark Maurer

Companies will have to disclose more details about the income taxes they pay to government authorities under new requirements approved by the Financial Accounting Standards Board, a move to provide investors with greater transparency.

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German Coalition Agrees to Cut Corporate Taxes by €7 Billion a Year

  • By William Hoke

Germany’s ruling coalition has agreed to cut corporate taxes by approximately €7 billion a year to stimulate the economy and promote long-term investment during a slowdown in business activity.

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New Zealand Pushes Ahead With Digital Services Tax for 2025

  • By Stephanie Soong

The New Zealand government will soon propose legislation for a digital services tax, citing slow progress on an OECD global tax reform agreement aimed at addressing the tax challenges of the digital economy.

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Silicon Valley Asks IRS to Extend Foreign Tax Credit Relief

  • By Andrew Velarde

A prominent interest group representing scores of large multinational companies is asking the IRS to go further with its temporary relief from foreign tax credit rules that businesses have sharply criticized.

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Pillar 2 Tax Discourse Helps ASEAN Readiness, Ministers Say

  • By Stephanie Soong

A recent discussion among Association of Southeast Asian Nations members about OECD-brokered global minimum tax rules and their implications for investment incentives will help countries in the region prepare accordingly, finance ministers said.

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