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IRS Official: No Easy Answers on Cost Sharing, Cash Boxes
There are no easy answerswhen it comes to cost sharing, an IRS official said in response to a question about the OECD's crackdown on "cash boxes" and its impact on cost sharing as defined under the tax regulations.
For the DTR story, go here. (subscription required)
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New IRS Guidance on Corporate Inversions Mostly Prospective
The IRS issued new guidance to continue the government's battle against inversion deals that let U.S. companies move their addresses outside the U.S. to reduce taxesÔøΩguidance that is for the most part prospective, but signals the government's intense efforts to make these deals tougher and less attractive.
For the DTR story, go here. (subscription required)
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Treasury Department and IRS further limit 'inversions,' but not through restricting deductions
The Treasury Department and IRS today issued Notice 2015-79 (the Notice), promising further regulations to limit cross-border merger transactions that the government characterizes as 'inversions.' The Treasury and IRS also issued a press release publicizing the Notice and a Fact Sheet summarizing the Notice's key points.
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Fact Sheet: Additional Treasury Actions to Rein in Corporate Tax Inversions
Treasury on November 19 issued a fact sheet regarding corporate inversions.
For the fact sheet, go here.
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Treasury Announces Additional Actions to Reduce Tax Benefits of Corporate Inversions
Today, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued a notice that takes additional steps to reduce the tax benefits of – andwhen possible, stop – corporate inversions. U.S. companies are currently taking advantage of an environment that allows them to move their tax residence overseas to avoid paying taxes,without making significant changes in the nature of their overall operations. Last year, Treasury took targeted steps to address this issue, and this notice identifies additionalways to reduce the incentives to invert.
For the Treasury release, go here.
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Remarks by Treasury Secretary Jacob J. Lew on a Press Conference Call Regarding Announcement on Corporate Tax Inversions
Treasury Secretary Jacob J. Lew delivered prepared remarks on a press conference call regarding Treasury's announcement on corporate tax inversions.
For the release, go here.
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US Treasury unveils new measures to deter tax inversions
The Obama administration has unveiled new measures aimed at deterring tax-cutting corporate transactions such as Pfizer's potential $150bn deal to buy Dublin-based Allergan.
For the Financial Times story, go here.
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U.S. Unveils Rules to Make Corporate Inversions More Difficult
The Treasury Department on Thursday released new rules to restrain U.S. companies from putting their addresses in foreign countries to reduce their tax bills.
The changeswill make it harder for U.S. companies to buy a company in one foreign country and locate the combined entity's address in a different country. They alsowould limit companies' maneuvers before a merger to make a foreign company look bigger and thus escape existing U.S. tax restrictions.
For thewall Street Journal story, go here.
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Wyden Statement Regarding New Treasury Guidance on Inversions
Senate Finance Committee Ranking Member Ronwyden, D-Ore., today issued the following statement following the release of new anti-inversion guidance.
For the statement, go here.
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Hatch Statement on Latest Anti-Inversion Tax Guidance from Treasury
Senate Finance Committee Chairman Orrin Hatch (R-Utah) today issued a statement after the U.S. Treasury Department announced new targeted guidance on corporate tax inversions:
For the statement, go here.
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Chairman Brady Calls for Tax Reform to Tackle Inversions
Houseways and Means Chairman Kevin Brady (R-TX) released a statement in response to a notice from the U.S. Treasury Department and the Internal Revenue Service (IRS) on measures to curtail corporate tax inversions.
For the statement, go here.
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Levin Welcomes Treasury Action on Tax Inversions
Ways and Means Committee Ranking Member Sander Levin (D-MI) issued a statement after the U.S. Treasury Department and the Internal Revenue Service (IRS) issued a notice that takes additional steps to curb corporate tax inversions.
For the statement, go here.
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Treasury Department and IRS further limit 'inversions', but not through restricting deductions
The Treasury Department and IRS today issued Notice 2015-79 (the Notice), promising further regulations to limit cross-border merger transactions that the government characterizes as 'inversions.' The Treasury and IRS also issued a press release publicizing the Notice and a Fact Sheet summarizing the Notice's key points.
For the PwC Insight, gohere.
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Fact Sheet: Additional Treasury Actions to Rein in Corporate Tax Inversions (1)
Treasury on November 19 issued a fact sheet regarding corporate inversions.
For the fact sheet, go here.
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Treasury Announces Additional Actions to Reduce Tax Benefits of Corporate Inversions (1)
Today, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued a notice that takes additional steps to reduce the tax benefits of – andwhen possible, stop – corporate inversions. U.S. companies are currently taking advantage of an environment that allows them to move their tax residence overseas to avoid paying taxes,without making significant changes in the nature of their overall operations. Last year, Treasury took targeted steps to address this issue, and this notice identifies additionalways to reduce the incentives to invert.
For the Treasury release, go here.
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Remarks by Treasury Secretary Jacob J. Lew on a Press Conference Call Regarding Announcement on Corporate Tax Inversions (1)
Treasury Secretary Jacob J. Lew delivered prepared remarks on a press conference call regarding Treasury's announcement on corporate tax inversions.
For the release, go here.
Posted on
US Treasury unveils new measures to deter tax inversions (1)
The Obama administration has unveiled new measures aimed at deterring tax-cutting corporate transactions such as Pfizer's potential $150bn deal to buy Dublin-based Allergan.
For the Financial Times story, go here.
Posted on
U.S. Unveils Rules to Make Corporate Inversions More Difficult (1)
The Treasury Department on Thursday released new rules to restrain U.S. companies from putting their addresses in foreign countries to reduce their tax bills.
The changeswill make it harder for U.S. companies to buy a company in one foreign country and locate the combined entity's address in a different country. They alsowould limit companies' maneuvers before a merger to make a foreign company look bigger and thus escape existing U.S. tax restrictions.
For thewall Street Journal story, go here.
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Wyden Statement Regarding New Treasury Guidance on Inversions (1)
Senate Finance Committee Ranking Member Ronwyden, D-Ore., today issued the following statement following the release of new anti-inversion guidance.
For the statement, go here.
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Hatch Statement on Latest Anti-Inversion Tax Guidance from Treasury (1)
Senate Finance Committee Chairman Orrin Hatch (R-Utah) today issued a statement after the U.S. Treasury Department announced new targeted guidance on corporate tax inversions:
For the statement, go here.
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Chairman Brady Calls for Tax Reform to Tackle Inversions (1)
Houseways and Means Chairman Kevin Brady (R-TX) released a statement in response to a notice from the U.S. Treasury Department and the Internal Revenue Service (IRS) on measures to curtail corporate tax inversions.
For the statement, go here.
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Levin Welcomes Treasury Action on Tax Inversions (1)
Ways and Means Committee Ranking Member Sander Levin (D-MI) issued a statement after the U.S. Treasury Department and the Internal Revenue Service (IRS) issued a notice that takes additional steps to curb corporate tax inversions.
For the statement, go here.
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Warren: End Rigged Game So Corporations Pay More Tax
Congress must permanently increase tax revenues from large corporations and end "loopholes" and "gimmicks" unavailable to small businesses, Sen. Elizabethwarren (D-Mass.) said at a National Press Club forum.
For the DTR story, go here. (subscription required)
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Repatriation a 'Giant Wet Kiss' for Tax Dodgers, Warren Says
Recent bipartisan international tax reform proposals under consideration in Congress received scathing criticism November 18 from Sen. Elizabethwarren, D-Mass.,who called deemed repatriation a "giantwet kiss" and the innovation box a "gift for lazy" U.S. companies that have moved their headquarters to lower-tax countries.
For the TNT story, go here. (subscription required)
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Candidates Seek High Return From Repatriation Policies
To hear some presidential candidates tell it, if itwere suddenly easy from a tax standpoint for U.S. corporations to repatriate more than $2.1 trillion in overseas earnings, the moneywould be in the nextwire transfer home, giving the economy a jump-start like none before.
For the TNT story, go here. (subscription required)
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Additional Anti-Inversion Guidance Coming This Week, Lew Says
"Additional targeted guidance" thatwould further deter and reduce the economic benefits of corporate inversionswill be coming later thisweek, Treasury Secretary Jacob Lew said November 18.
For the TNT story, go here. (subscription required)
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Lew Says New Inversions Guidance Coming This Week
The Treasury Departmentwill be issuing "additional targeted guidance" thisweek to cut back corporate inversions, Treasury Secretary Jacob J. Lew told lawmakers in a letter obtained by Bloomberg BNA.
For the DTR story, go here. (subscription required)
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N. Ireland to Cut Corporate Tax to 12.5 Percent in 2018
Northern Irelandwill cut its corporate tax rate to 12.5 percent in April 2018 to attract foreign direct investment and better competewith neighboring countries, including the Republic of Ireland.
For the DTR story, go here. (subscription required)
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ANALYSIS: India's movement towards a non-adversarial tax regime
It iswell-documented that the Indian Government has been making efforts to promote a non-adversarial tax regime in India, but are taxpayers feeling a knock-on impact already?
For the ITR story, go here.
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A Sad Reality Of Cross-Border Mergers And Acquisitions
In prior articles,we've referenced military theoretician Carl von Clausewitz. Strangely enough, passages in his seminalwork "Onwar" have an effect on cross-border mergers and acquisitions of today.
The effect is not limited to the mega-deals that have been so prominent over the past two years. It touches middle-market M&A and even small deals. The population of middle-market and start-up companies is obviously far greater than large-cap companies. Given this, in terms of numbers as opposed to dollars, it is understandable that cross-border M&A is a bigger issue for the middle-market and small business.
For the Forbes story, go here.
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Treasury poised to issue new tax guidance
The Treasury Department is preparing to release guidance thisweek in an effort to curb "inversions," a practice allowing U.S. firms to reduce their taxes by basing their operations overseas.
For The Hill story, go here.
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NYSBA Group Urges Fewer Benefit Limits in Model Tax Treaty
The proposed new limitation on benefits article in the U.S. model tax treaty goes too far in reducing access to these tax pacts, and the government should narrow those restrictions, the New York State Bar Association Tax Section said.
For the DTR story, go here. (subscription required)
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European Commission Tax Reporting Proposal Coming in 2016
The European Commission's proposal for mandatory country-by-country tax reporting by companies and legislationÔøΩcoming in MarchÔøΩwill go beyond the OECD's base erosion and profit shifting plan and require that the details of taxes paid by companies in individual countries be public, a commission official said.
For the DTR story, go here. (subscription required)
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U.S. Business Coalition Pushes for Tax Overhaul After BEPS
Some of the most profitable technology firms in the U.S. have formed a coalition to push for a U.S. international tax overhaul in thewake of the OECD's completion of its action plan on base erosion and profit shifting.
For the DTR story, go here. (subscription required)
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BEPS tax reforms cannot be the endpoint, G20 told
The OECD's base erosion and profit shifting (BEPS) reforms do not go far enough in changing the international corporate tax system, G20 leaders have been told.
In a letter to leaders at the G20 summit in Antayla, Turkey, Nobel Prize-winning economist Joseph Stiglitz and others from the Independent Commission for the Reform of International Corporate Taxation (ICRICT) said that,while a good start, reforms need to go much deeper to ensure multinational corporations pay their fair share.
For the Public Finance International story, go here.
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MNEs Defend Operations at EU TAXE Committee Hearing
Appearing before a special European Parliament tax rulings committee, representatives of multinational enterprises expressed support for the OECD'swork in crafting guidelines to combat base erosion and profit shiftingwhile defending their operations and voicing concernswith the public disclosure of information.
For thewWTDS story, go here. (subscription required)
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IMF repeats GCC tax reform calls; VAT a case of 'when', not 'if'
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LOB Provisions in the 2015 Draft U.S. Model Tax Treaty
In this report, Stone examines proposals by Treasury,whichwere releasedwithout a technical explanation, to modify the U.S. model treaty provisions that affect the limitation on benefits article.
Stone believes that given the rules-based nature of the LOB article, new rules are needed as taxpayers findways around the old ones and as the nature ofwhat Treasury believes to be treaty abusive -- such as low resident state tax treatment of income -- evolves. Stone discusses the provisions,with examples, and tries to make sense of them. In the end, he finds that the size and complexity of the LOB proposals suggest that a principal purpose test approach isworth considering.
For the Tax Notes special report, go here. (subscription required)
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EU Quizzes Facebook, Google on Dutch Sandwich' Tax Deals
Google Inc. and Facebook Inc.were among U.S. companies facing questions from European Union lawmakers about their tax-reducing techniques, a month after regional antitrust regulators raised the stakes by ordering Starbucks Corp. and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes.
For the DTR story, go here. (subscription required)
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G-20 Leaders Endorse OECD Tax Evasion Package
Leaders from the Group of 20 nations endorsed the final results of the Organization for Cooperation and Economic Development's effort to combat corporate tax avoidance during their annual summit in Antalya, Turkey.
The G-20 members said the OECD's final base erosion and profit shifting action planwill help reach a "globally fair and modern international tax system," according to their Nov. 16 communique.
For the DTR story, go here. (subscription required)
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MEPs give digital firms hard time on tax
Digital companies continue to get a rough ride from the EU. Hot on the heels of a European Commission decision to open an investigation into Google for allegedly breaching antitrust rules, EU lawmakers Monday targeted 11 companies ÔøΩ including Google, Facebook and Amazon ÔøΩ for their tax policies in Europe.
For the Politico story, go here.
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Tough debate with multinational companies on corporate tax practices
MEPs grilled eleven multinational companies on their corporate tax practices in a five-hour debatewith the Special Committee on Tax Rulings on Monday. These companies had declined the committee's first invitation to appear before it, but later changed their minds and accepted its last chance invitation. Of the 13 original invitees, only Fiat Chrysler andwalmart declined the final invitation. The meeting startedwith a minute of silence for the victims of the Paris terrorist attacks.
For the European Parliament release, go here.
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G20 leaders endorse OECD measures to crack down on tax evasion, reaffirm its role in ensuring strong, sustainable and inclusive growth
At their Summit in Antalya, Turkey, the G20 leaders committed to the implementation of theBase Erosion and Profit Shiftingproject (BEPS)which closes gaps that allow corporate profits to "disappear" or to be artificially shifted to low or no tax environments. They called on the OECD to monitor progress and to develop, by early next year, an inclusive framework including the participation of developing economies on equal footing.
For the OECD release, go here.
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Taxing issue: multinationals respond to EP proposals to make them pay their fair share
Jean-Claude Juncker, president of the European Commission, told the tax rulings committee that something needed to be done. "The current system of corporate tax rules is unfit for purpose and unjust. Some companies are losing out,whereas otherswin by hiding behind a variety of national rules," he said at the committee's September meeting. Juncker stressed that the fight against tax fraud and tax evasionwas one of the Commission's priorities.
For the European Parliament release, go here.
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Economic Analysis: The Rise of the Intangible Economy
The U.S. economy is changing, and how the government measures it is starting to catch up. In its 2013 revision of the national income and product accounts, the Commerce Department's Bureau of Economic Analysis (BEA) expanded its measurement of intangible investment. Previously the only spending on intangible assets that the BEA countedwas on computer software (and a relatively minor amount of spending on mineral exploration). The revised official accounts now include spending on research and development and on artistic originals -- mostly motion picture and sound recordings.
For the Tax Notes article, go here. (subscription required)
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G-20 Leaders Set to Approve Overhaul of Corporate-Tax Rules
A push to close international corporate-taxloopholes is expected to spur competition for lower rates overseas and increase pressure inwashington for a bipartisan deal to revamp the corporate-taxcode.
Leaders from theGroup of 20largest economies, meeting in Turkey on Sunday and Monday, are set to give their final stamp of approval to a major overhaul of the international rules governing corporate taxes.
For thewall Street Journal story, go here.
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A Tax-Cutting Move That Pfizer Can Hardly Resist
Give Pfizer, the giant drug maker, points for boldness and persistence: The company has bravely put ''taxinversions'' back in the headlines.
Pfizer,which already holds roughly $140 billion overseas and is quite skillful at minimizing its taxes, is considering a deal that could move its legaltaxheadquarters from New York to Dublin,where it could save bundles more.
This has drawn plenty of criticism, naturally.
For the New York Times story, go here.
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After Outcry, Ireland Adjusts Its Corporate Tax Draw
As lord mayor of this quiet seaside city in southern Ireland, Chris O'Leary seems to have a situation most other local politicians can only dream about.
Blue-chip international companies like Apple,DellandIBMhave all set up shop in and around this city, filling newly built office blocks near the city's port and sprawling office parks in the suburbs. The companies set up shop here for the cheapworkers, business-friendly lawmakers and -- above all -- Ireland's low corporatetaxrate. Since the height of the financial crisis in 2011, the region's unemployment rate has fallen by more than four percentage points, to 9.9 percent, or roughly the national average, according to government statistics.
For the New York Times story, go here.
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OECD holds first Asia-Pacific Technical Meeting on BEPS in Indonesia
The OECD has held an Asia-Pacific technical meeting on BEPS inwhich tax policy and administration experts discussed outcomes of the base erosion and profit-shifting project and challenges of implementing BEPS measures in the region, according to a November 13 release.
For the release, go here.
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News Analysis: $240 Billion More in BEPS Taxes -- Who Wins? Who Loses?
Mindy Herzfeld reviews the conclusions reached in the final report on BEPS action 11 and discusses the shortcomings in the OECD's attempts to quantify the extent of the problem, aswell as the potential for governments to recoup additional tax revenues as a result of the recommendations and the potential consequences to economies around theworld.
For the TNI story, go here. (subscription required)