2016

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AICPA Submits International Tax Reform Comments To House Ways and Means Committee Chairman Brady

by Troy K. Lewis
Troy K. Lewis of the American Institute of CPAs in a June 23 letter to Houseways and Means Committee Chair Kevin Brady, R-Texas, made recommendations and sought technical clarifications on the international tax provisions of the Tax Reform Act of 2014, such as changes to the foreign tax credit system and FICA taxes for foreignworkers.
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U.S., Luxembourg in Treaty Talks to Close Tax Break

by Alison Bennett
Luxembourg's efforts to show theworld it is cooperating in shutting down double nontaxation are likely to continue, as the country faces increasing criticism in both Europe and the U.S.
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Canada Court OKs Mark-to-Market for Foreign Exchange Options

by Peter Menyasz
Income earned from foreign exchange option contracts may be calculated on a mark-to-market basis for income tax purposes, Canada's Federal Court of Appeal confirmed (Kruger Inc. v. the Queen, Canadian Fed. Ct. of App., No. A-296-15, 6/22/16).
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South Africa proposes carbon tax relief in draft law

by Amelia Schwanke
South Africa is pushing aheadwith a proposed carbon tax thatwill increase the tax burden for companies, but a carbon offset could offer somewelcome tax relief.
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EU Parliament to vote on ambitious call to rewrite EU tax system

International Tax Review
Companies operating in the EU may face an EU-widewithholding tax and a host of new compliance and tax regulations if the EU approves recommendations by the Special Committee on Tax Rulings.
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video: Exclusive interview with Pascal Saint-Amans

by Amelia Schwanke
Pascal Saint-Amans, director of the Centre for Tax Policy and Administration at the OECD, sat downwith International Tax Review reporter Amelia Schwanke to discuss the most prominent topics in tax because although "tax isn't fun, it's absolutely fundamental if youwant to have services to the population".
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Leading Democrats, Republicans Split on House GOP Proposed Tax Reform

by Evan Fallor
The House GOP blueprint for tax reform released Friday sparked mixed reactions in Congress,with leading Democrats criticizing its lack of detail and Republicans lauding its proposed pro-growth efforts through limits on deductions, exclusions and credits in the current tax code.
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Countries Gear Up For Key BEPS Meeting

by Mary Swire
The OECD's Committee on Fiscal Affairswill hold its first meeting under its new inclusive framework for non-OECD and non-G20 territories to discuss the next step on base erosion and profit shifting (BEPS).
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Tax policy after Brexit

by Richard Teather
The opinion pollswerewrong again; Brexit haswon. But now the hardwork begins of building alternative structures, and decidingwhat to dowith the UK's new freedom of independent action.
One aspect that didn't get a mention in the campaignwas the huge extent towhich the EU already influences the UK's tax agenda.
The next couple of yearswill determinewhether the post-Brexit UK becomes an outward-looking global economy or retreats into nationalistic tariffwars.
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India amends application date of General Anti-Avoidance Rule

by Amelia Schwanke
Investors in India have been given room to breathe as the Central Board of Direct Taxes (CBDT) amends the effective date of the General Anti-Avoidance Rule (GAAR).
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Brexit Seen Boosting EU Drive to Harmonize Corporate Tax

Bloomberg

by Joe Kirwin
The U.K.'s exit from the European Union is expected to strengthen the drive led by Germany and France to harmonize corporate tax policyÔøΩespeciallywhen it comes to an upcoming attempt to revitalize a plan to develop a single set of rules thatwould allow cross-border companies to file a single tax return for their EU activities, according to European Parliament members, tax practitioners and some academics.
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Germany publishes draft bill implimenting BEPS related measures

  • By PwC

PwC

by PWC
The German Federal Ministry of Finance on June 1, 2016, published a draft billwhich implements the EU directive mandating the automatic exchange of tax information in addition to measures targeting base erosion and profit shifting (BEPS). The bill's main legislative changes include the adoption of the Organization for Economic Co-operation and Development's (OECD's) recommendations for country-by-country reporting (CbCR) and the 'Master File/Local File' concept for transfer pricing (TP) documentation.
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US and Luxembourg announce retroactive change to triangular branch rules in treaty

  • By PwC

PwC

The US and Luxembourg on June 22, 2016, agreed to amend a protocol to the existing income tax treaty that addresses the potential for double non-taxation for US-source income of a Luxembourg company attributable to its US branch. parliamentary action, the timing ofwhich is uncertain, but could be as early as late June 2016.The amendment affects the 'triangular branch rule' for taxpayers using US branches taxed in neither the US nor Luxembourg.
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House Republicans outline plan for comprehensive tax reform

  • By PwC

PwC

House Republicans today released a 35-page report on tax reform that proposes to lower corporate and pass-through business tax rates, reduce individual tax rates, provide full expensing for business costs (with no deduction for net business interest expense), and move the United States from aworldwide international tax system to a 'territorial' dividend-exemption system.
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Is Corporate Integration a Good Idea?

  • By Avi-Yohah

In this installment of the Star Forum, expertsweigh in on the following question:

Senate Finance Committee Chair Orrin G. Hatch, R-Utah, has announced that he is drafting a proposal in favor of corporate integration. Do you think that corporate integration is a good idea?what factors should Hatch consider as he is drafting his proposal?
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Germany Agrees to Toughen Inheritance-Tax Rules

by Ruth Bender and Andrea Thomas (Wall Street Journal)
Germany's ruling coalition agreed to restrict tax exemptions on some corporate successions, allowing them only for smaller companies or those in difficulty, after months of debate overwhat critics have called lopsided policies that benefit mainly the country's richest families.
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10 Observations Concerning International Tax Policy

Daniel Shaviro, thewayne Perry Professor of Taxation at New York University Law School, presents a slightly revised version of a luncheon talk he gave at the National Tax Association's 46th annual spring symposium on May 12.

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Do U.S. Income Tax Treaties Override The Section 4985 Anti-Inversion Tax on NRA Insiders?

Bloomberg

by Thomas S. Bissell
CPA Thomas Bissell examines the possibility that U.S. income tax treaties may override application of the tax code Section 4985 excise on "insiders" of expatriating corporations for nonresident aliensworking mostly or entirely outside the U.S.
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IRS Makes Changes to Corporate Inversion Rules

  • By Bloomberg

Bloomberg

by Bloomberg
The IRS corrected guidance related to efforts to limit U.S. companies from changing their tax residence to cut or avoid U.S. taxes.
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U.S. Corporate Tax Is Driving Inbound Acquisitions, Panel Says

by Ryan Finely (Tax Notes)
The United States' high corporate income tax rate and extraterritorial system are major contributors to a recent surge in acquisitions of U.S. companies by foreign multinationals, according to a panel of economists.
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Speech by Commissioner Pierre Moscovici at the Tax Congress of the Berlin Tax Forum 2016

  • By Commissioner Pierre Moscovici
European Commission Commissioner Pierre Moscovici delivered a speech on Europe's latest initiatives on corporate tax policy at the Tax Congress of the Berlin Tax Forum 2016.
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Commission welcomes agreement on new rules to tackle tax avoidance

  • By European Commission

The Commission haswelcomed the agreement reached by Member States on their general approach for far-reaching new rules to eliminate the most common corporate tax avoidance practices.

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Switzerland: The Swiss tax function of tomorrow.

International Tax Review

by Andre Claes, David McNeil and Sarah Drye

The evolution of the global tax environment is forcing international tax functions to consider new and innovativeways of effective managemen

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The Case for Not Eliminating the Corporate Income Tax

by Scott Greenberg (Tax Foundation)
This past Friday, two prominent tax economists released a detailed and thoughtful tax reform proposal, calling for a major overhaul of the U.S. corporate income tax.
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OECD Backs US International Tax Reform Efforts

  • By Ulrika Lomas
by Ulrika Lomas (Tax News)
The Organisation for Economic Co-operation and Development has, in its recent economic survey of the United States,welcomed steps taken by the Government to reform the country's international tax system.
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EU agrees corporate tax avoidance rules

by Emma Rumney (Public Finance International)
New rules to combat corporate tax avoidance by multinational companies are to be adopted across the European Union after member states agreed a package of measures today.
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EU agrees on rules to tackle multinational tax avoidance

International Tax Review

by Anjana Haines
European finance ministers have finally agreed on plans to crack down on aggressive tax planning by multinationalswith the proposed Anti-Tax Avoidance Directive.
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EU struggles to close tax loopholes with new law

EU states have cleared a deal that aims to close some of the loopholes used by large companies to dodge taxes.
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Weighing The Corporate Tax Implications Of A 'Brexit'

Forbes

by Joe Harpaz
While there have been hundreds of articles chronicling the arguments for and against the Brexit and gauging the potential impacts to the British economy and to individual Britons, less has been done to examine the possible corporate tax implications of the move.
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Will BEPS Be a Game-Changer as OECDs Pascal Saint-Amans Claims?

It has been said on more than one occasion that, in the area of international taxation generally, the OECD/G20 Base Erosion and Profit Shifting (BEPS) projectwill be a game-changer. Pascal Saint-Amans, director of the OECD Center for Tax Policy and Administration, recently reiterated the claim in an interviewwith Axel Threlfall, Reuters editor-at-large, at the recent OECD Ministerial Council Meeting in Paris.
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Corporate taxation: MEPs call for tax haven black list, patent box rules, CCCTB and more

by Ron Korver (European Parliment)

Recommendations to make corporate taxation fairer and clearerwere voted by the Special Committee on Tax Rulings II on Tuesday evening. They call for an EU public register of beneficial owners of companies, a tax havens blacklist, sanctions against non-cooperative tax jurisdictions, action against abuse of "patent box" regimes, a code of conduct for banks and tax advisors, tax good governance rules in all EU trade agreements and awithholding tax on profits leaving the EU.

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Brexit: What would it really mean for tax?

International Tax Review

by Tim Sarson

Tim Sarson, a tax partner at KPMG in the UK, explainswhy tax professionals should probably ignore much of the noise around 'Brexit', at least for the time being. This clears the path for companies to focus on the changes that really matt

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here.

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Brexit: Britan, the EU and the most worried tax implications

International Tax Review

If the UK votes to leave the European Union (EU) on June 23 multinationals face an urgent problem: how to copewith uncertainty in the tax system.

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Cross-Border Tax Avoidance Likely IRS Audit Campaign Target

The IRS's new technique of selecting tax issues to scrutinize via "campaigns" is likely to have a sharp focus on cross-border tax evasion through transfer pricing and treaty manipulation.
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States Show Why Tax Havens Are Wonderful': Economist Laffer

Economic growth in stateswith no income tax exemplifieswhy being a "tax haven iswonderful," economist Arthur Laffer said.
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EU Anti-Tax Avoidance Deal Clears Legislative Hurdle

by Joe Kirwin
The European Commissionwill begin a monitoring exercise to determinewhether the U.S., Japan and China adopt OECD strategies to combat profit shifting, after the commission reached an agreement to crack down on corporate tax avoidance.
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Counterproductive Treasury Inversion Policy

by George Ill Nastas
George Nastas III explains how corporate inversions are a symptom of bad U.S. tax policy andwhat the government could do to make U.S. businesses more competitive.
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European Council Approves Compromise Anti-Tax-Avoidance Directive

Following the lapse of the deadline for member states to raise any final objections, the European Council has approved a laxer version of the anti-tax-avoidance directive proposed by the European Commission in January.
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TAXE II Recommends EU-Wide Ownership Register, Tax Haven Blacklist

by J.P. Finet
An EU-wide register of beneficial ownership, a tax haven blacklist, sanctions against noncooperative jurisdictions, and actions to stop the abuse of patent box regimes top the recommendations in the final report of the European Parliament's special committee on tax rulings.
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Rand Paul, Others Ask Treasury to Renegotiate Tax Treaties

byKevin A. Bell
Three Republican members of the Senate Foreign Relations Committee asked the Treasury Department to renegotiate the information exchange articles of pending U.S. tax treatieswith Chile, Hungary, Japan, Luxembourg, Poland, Spain and Switzerland.
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Bank: Give Debt-Equity Relief to Foreign Business in U.S.

by Alison Bennett
Foreign banks and foreign corporations doing business in the U.S. should get a break in the final version of controversial rules intended to curb multinationals from stripping income out of this country via loans to subsidiaries, a European bank said.
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Taxing concerns over Brexit: VAT perspective

With a referendum looming, UK voters are now under pressure to decidewhether to remain in the EU.

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OECD Council approves incorporation of BEPS amendments into the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

  • By OECD

On 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ("Transfer Pricing Guidelines"), as set out in the 2015 BEPS Report on Actions 8-10 "Aligning Transfer Pricing Outcomeswith Value Creation" and the 2015 BEPS Report on Action 13 "Transfer Pricing Documentation and Country-by-Country Reporting". These amendments provide further clarity and legal certainty about the status of the BEPS changes to the Transfer Pricing Guidelines,whichwere endorsed by the Council on 1 October 2015, by the G20 Finance Ministers on 8 October 2015, and by the G20 Leaders on 15-16 November 2015.

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Can Treasury Bully Corporations Into Shaping Up Their Debt?

by Jasper L. Cummings, Jr.
In this report, Cummings focuses on the collateral consequences of the proposed section 385 regulations. He provides a chart showing the sorts of groups the various parts of the regulationswould apply to, and he lists 20 of the more common transactions that could be affected by the regulations.
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Leverage Tax to Make Decentralization Work, OECD Says

by Stephanie Soong Johnston
State and local governments' autonomy to set rates and their own tax bases is growing, but key steps to make devolution effective -- such as aligning subnational governments' taxation and spending powers, aswell as reforming property tax systems -- are necessary, the OECD said.
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Ownership, Control, and the Arm's-Length Standard

by J. Gregory Bellentine
J. Gregory Ballentine contends that the OECD's recommendations in its final base erosion and profit-shifting report on actions 8-10 do not go far enough in addressing the transference of intangible asset rights from U.S. multinationals to subsidiaries in tax havens.
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Consolidation Will Come After Common Tax Base Is Secured, Moscovici Says

by J.P. Finet
While acknowledging concerns over the European Commission's two-step approach to relaunching its common consolidated corporate tax base proposal, EU Tax Commissioner Pierre Moscovici assured businesses that hewill deliver the consolidation they are eagerly awaiting once the common base is secured.
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VAT Complications Would Likely Follow British Exit From EU

by Penny Sukhraj
If Britons vote to leave the European Union on June 23, uncertainty over value-added taxation and likely changes to the tax compliance framework could prove complicated for companieswith U.K. ties that tradewithin the 28-nation EU bloc.
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EU's Vestager: Tax Avoidance Fight Remains Priority

by Linda A. Thompson
Competition Commissioner Margrethe Vestager said the European Commission's efforts to tackle harmful tax competition have "started to deliver results" in the last six months.
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News Analysis: State Aid Bureaucrats Run Amok

by Mindy Herzfeld
Mindy Herzfeld reviews the European Commission's recently released state aid rulings and its public explanations for the ongoing state aid investigations and considerswhether they reflect a bureaucracy run amok.
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