Int'l Tax News

France's promised business tax cutwill be delayed nine months according to its budget released Sept. 24.

Canadian manufacturerswant the government to offer fullwrite-offs for machinery and assets in a bid to keep upwith the changes included in U.S. tax reform.

Businesses should review existing stapled structures, set up to convert trading income into more favorably taxed passive income, as Australia's government moves a bill through parliament to crack down on the practice.

The IRS has announced that the advance pricing and mutual agreement program has reorganized to consolidate the program's resources to improve internal processes, resolve disputes, and increase taxpayer service.

In this article, the author discusses the growing use of cross-border audits, examining their connection to the push for transparency and how they operate bothwithin and outside the European Union. She addresses concerns about taxpayer secrecy, the potential benefits for both tax authorities and taxpayers, and discusses how taxpayers can prepare to face this new form of audit.

In this article, the authors discuss Alta Energy, inwhich the Tax Court of Canada held that a Luxembourg company's sale of shares in a Canadian shale development company to Chevron Inc.was exempt from capital gains tax as treaty-protected property under the Canada-Luxembourg treaty.

Too many EU tax treaties unfairly restrict developing countries' source taxing rights, and EU member states should reexamine and renegotiate those treaties to effectively lead on policy coherence for development, a new report says.

German Chancellor Angela Merkel told business leaders she is in favor of ending the reunification tax for all taxpayers, and that Germany can't "simply decouple" from theworld in thewake of U.S. corporate tax reform.

The European Commission's finding that McDonald's didn't receive illegal state aid from Luxembourg doesn't mean there is nothingwrongwith the EU tax system, EU Competition Commissioner Margrethe Vestager said.

Treasury may be trying to blunt some practitioner criticism about the potential breadth of the global intangible low-taxed income provision's pro rata share antiabuse rule, including its capacity to catch older transactions.

It's hard not to notice the newest employees at South Korea's Incheon International Airport. They're extremely polite, they can help passengers find their gates, and they're more than happy to take photoswith passengers. And each of them is fluent in four languages: Chinese, English, Japanese, and Korean.

Competition Commissioner Margrethe Vestager said in a September 24 speech in Vienna that she has "asked three experts to look into the implications of the future of digitization for competition policy," and theywill present their findings and recommendations next March.

The Court of Justice of the European Union has published the reference for a case (C-458/18) onwhether provisions under article 2 of the EU parent-subsidiary directive (2011/96/EU) should be interpreted to mean that the expression "companies incorporated under the law of the United Kingdom" applies to companies incorporated in Gibraltar.

Many of theworld's major financial centers are undermining other countries' tax laws and facilitating crime and corruptionwithout having toweather a listing on the EU's tax haven blacklist, according to new research.

An administrative appeals panel has reversed a decision by Brazil's Federal Tax Service (RFB),which denied awhirlpool subsidiary's deduction of an embezzlement loss on grounds that the unit's directorwas not awhirlpool employee.

A higher corporation tax ratewith a reduced rate for small businesses and greater transparency are among the proposals the Labour Partywants to introduce to make the U.K. tax system fairer.

Tax campaigners and academics have boycotted the KPMG "responsible tax" event this pastwednesday over concerns about the firm's past role in helping large multinational companies minimize their tax bills and the inclusion of a rightwing think-tank as a prominentspeaker. The eventwas billed as an "idea exchange"where a range of participants including politicians, academics, campaigners, and policymakerswould discuss the topic of "responsible tax".

Companies' record stock repurchases this year are causing profits to appear stronger and fueling the stock market's record run. A key driver in the surge of stock buybackswas last December's tax overhaul,which lowered companies' tax bills and freed up funds that many companies are using for share repurchases.

Peruvian President Martín Vizcarra on September 13 signed a legislative decree implementing the general antiavoidance rule introduced into Peruvian legislation on July 19, 2012.

A draft resolution recently released by European Union lawmakers contains an amendment thatwould let individual countries decide the percentage of a tax to be imposed on large digital companies.

Although proposed regs fail to completely resolve ambiguity surroundingwhether business interest limitations apply for purposes of calculating global intangible low-taxed income, until stated otherwise, they are arguably applicable.

The IRS has proposed (REG-130244-17) removing final regulations (T.D. 9790) under section 385 that provide minimum documentation requirements for some related-party interests in a corporation to be treated as indebtedness for federal tax purposes and has proposed conforming changes to other final regs to reflect the proposed removal of the documentation rules.

Proposed regulationswithdrawing the debt-equity documentation ruleswill help large corporations avoid spending $924 million in compliance costs over 10 years, but burdens continuewith the remaining anti-inversion, anti-earnings-stripping rules.

Three years after the Organization for Economic Cooperation and Development came outwith its base erosion and profit shifting plan, most tax incentives regimes for intellectual property development are now compliant, signifying that, as one OECD official said, "everybody is moving in the right direction."

Federal Reserve Board Chair Paul Volcker used to carry in his pocket a little slip of paperwith hourly constructionwageswritten on it.

In this article, the authors discuss the Google and Conversant cases,which illustrate the application of French dependent-agent permanent establishment case law to digital economy companies.

The book explores a topic that has been highly controversial in recent years: the use by multinational companies of "base erosion and profit-shifting" tax planning structures to reduce their tax liabilities in countrieswhere they conduct business, including theworld's lower-income developing countries. In this installment,which is the sixth and final chapter, the author considers the challenges of generating the politicalwill necessary to implement measures to curtail profit shifting as it currently affects lower-income countries. The most recent installment appeared in Tax Notes Int'l, July 16, 2018, p. 255.

The European Commission's proposal to tax digital serviceswould be interpreted as a tariff and likely provoke U.S. retaliation, according to a German economic analysis.The European Commission's proposal to tax digital serviceswould be interpreted as a tariff and likely provoke U.S. retaliation, according to a German economic analysis.

The Court of Justice of the European Union in EV v. Germany, C-685/16 (CJEU 2018), held that restrictions that Germany places on the deductibility of distributions of profits from shareholdings in non-member-state companies violate EU treaty provisions regarding the free movement of capital.

German restrictions on the deductibility of distributions of profits from shareholdings in nonmember-state companies violate EU treaty provisions on the free movement of capital, the Court of Justice of the European Union has held.

The IRS has issued guidance (Notice 2018-72) announcing that itwill amend the section 871(m) final regulations to delay the effective date of some rules in those final regs, further extending the phase-in period provided in Notice 2016-76 for specified provisions of the section 871(m) regs, and extending some of the transition rules described in Notice 2010-46.

The IRS has further delayed some dividend equivalent regulations following continued outcry from practitioners about implementing the complicated regime.

The Netherlandswants you to know that it is not a tax haven. But Menno Snel, the country's No. 2 finance official, grudgingly acknowledges that the Dutch have become experts at something else: aggressive tax planning.

China's government is grapplingwith an inconvenient truth: you can't cut taxes, boost spending and reduce the budget deficit all at the same time.

Prime Minister Justin Trudeau's government could make meaningful progress in addressing the nation's competitiveness challenges evenwithout taking the costly step of lowering the corporate tax rate, according to the head of the country's biggest business lobby.

U.S. corporations are required to pay a one-time tax on their offshore profits, but don't expect those stockpiled funds to come onshore quicklyÔøΩor ever. Companies repatriated $169.5 billion in the second quarter, according to data released Sept. 19 by the Commerce Department, up from $34.9 billion a year earlier.

A Swiss bankwill have to repay millions for steering German international retailer Müller Holding Ltd. & Co. KG toward investing in an outlawed dividend-stripping scheme that involved the right to refunds of taxeswithheld from dividend payments.

Far-right Brazilian presidential hopeful Jair Bolsonaro's campaign onwednesdaywas sharply at oddswith the candidate's economic guru overwhether a loathed financial transactions taxwould return, exposing cracks in the front-runner's team.

McDonald's Corp.won a rare reprieve from European Union competition regulators cracking down on unfair fiscal deals for multinational firms. EU officials concluded that the pact between McDonald's and Luxembourg, that allowed the company to side step taxes on its profits, did not break the law.

Starbucks' European business paid an effective UK tax rate of just 2.8 per cent in the year to the end of October 2017 after a payment from another part of the group boosted profits.

FedEx Corp. is signaling to investors that the new proposed rules for the one-time tax on overseas assets could take a hit on its earnings.

Multinationals may not have seen the end of a rule that gives the IRS greater authority to decide how to value intercompany transfers of valuable assets. Temporary regulations that let the IRS broadly apply the "aggregation" method to value a multinational's intercompany transactions expired Sept. 14. But the IRS could still apply those concepts or make the regulations final because a version of those concepts appears in the 2017 tax law and in previous proposed regulations.

New Zealand's tax authority has slammed a report from anti-poverty group Oxfamwhich claims multinational drug companies avoided nearly $4 billion in taxes from 2013-15 by using tax havens to shift profits.

Australian mining giant BHP Billiton Ltd. says it paid $7.8 billion in global taxes and royalties in the 2018 financial year, $3 billion more than it paid the previous year. This is also the first year that BHP has disclosed its profits, number of employees, and effective tax rates in the key countries inwhich itoperates. This disclosure comes amid anti-avoidance groups' campaigns for companies to publicly disclose profits and taxes paid in the jurisdictions inwhich they operate.

"Our in-depth investigation has shown that the reason for double nontaxation in this case is a mismatch between Luxembourg and U.S. tax laws, and not a special treatment by Luxembourg," EU Competition Commissioner Margrethe Vestager said September 19 regarding the European Commission's decision on Luxembourg's compliancewith EU state aid rules.