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Tentative EU Antiavoidance Directive Drops Switchover Clause
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U.K. Tax Update: Brexit -- On the Edge of an Abyss, or a Great Step Forward?
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Treasury Could Delay Earnings-Stripping Rules to Year's End
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Inbound Investors Warned of Debt-Equity Regs and Model Treaty
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CRS Report: U.S. Patent Boxes May Encourage Profit Shifting
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Ten EU States to Meet on Financial Transactions Tax
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OECD Amending Business Restructuring Transfer Pricing Guidance
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Medtronic Ruling Back to the Future,' Tax Attorneys Say
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Brexit: Britain, the EU and the most worrying tax implications
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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Obama's Building A Wall Around Corporate America
During his first inaugural address, President Obama pledged to bridge the divide betweenwashington and Main Street America by making government accountable to the people.
Nearlyeight years later, that chasm has only grown greater, exacerbated by the steady consolidation of executive power and unbridled growth of the federal regulatory machine.
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Businesses want Treasury to revisit rules meant to keep firms in U.S.
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Mark as favoriteA proposal to reform the taxation of corporate income
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OECD Economic Surveys - June 2016
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Interpreting Tax Treaties
The circumstances, if any, that permit non-uniform, or differentiated, treaty interpretation are difficult to define. Generally, a differentiated approach stands in tensionwith the Vienna Convention's rules of interpretation,which apply a methodology based on plain meaning to all treaties. Yet courts, states, and scholarswidely accept the notion that some treatieswarrant special interpretive rules. Thus far, however, efforts to justify differentiated treaty interpretation on the grounds of subject matter or treaty purpose have proven inadequate. A more promising avenue is the examination of the objective characteristics sharedwithin a treaty type. One such characteristic, the author argues, is the treaty's degree of completeness. Specifically, all else being equal, standalone instruments call for less reliance upon extrinsic materials; interstitial instruments demand more.
Applying this insight to the tax treaty context, this Article argues that such instruments should not be viewed as complete; consequently, reference to plain meaning or even the treaty parties' mutual intent is often incoherent.
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OECD to Publish More BEPS Discussion Drafts, New Peer Reviews
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U.S. Should Reform Research Credit and Implement CRS, OECD Says
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Lawmakers Plan Response to Treasury's Debt-Equity Rules
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In Pursuit of Neutrality: Corporate Income Tax Integration
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OECD Tax Official: Countries Going It Alone on Digital Economy
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Manufacturers say lower corporate tax rate would boost their competitiveness
Manufacturers view a corporate tax rate of 25 percent or less, a long-term research and development tax credit, and robust cost-recovery provisions as essential elements of tax reform thatwould make them more competitive, according to survey results released Thursday.
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Kill-Switches in the New U.S. Model Tax Treaty
The new US model income tax treaty contains an unusual addition: mechanisms for the parties to unilaterally override the negotiated treaty rates in specified circumstances. Previewed last year in proposed form ÔøΩ a first for Treasury ÔøΩ these new mechanismswork as kill-switches, partially terminating the treaty as to one or both treaty partners. This Article analyzes the new kill-switch provisions and concludes that their introduction in the U.S. Model reflects the steady deterioration of tax treaties from essentially diplomatic documents premised on the good faith of the parties to detailed contracts drafted in anticipation of the opposite.
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Scrutinize Property Transfer Reporting Well, IRS Tells Agents
U.S. companies could face big penalties if they don't report property transfers to foreign corporationsÔøΩand the IRS is telling its agents to put that reporting under the microscope. The Internal Revenue Service issued detailed audit instructions to those agents as it increases its focus on companies that may seek to avoid taxes by moving property, such as stock, overseaswithout telling the government.
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Switzerland getting closer to major overhaul of business tax
Switzerland edged closer to implementing long-awaited business tax reforms on Tuesday,when the lower house of parliament approved proposals aimed at meeting global taxation standards.
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EU finance ministers to hold 'last-chance' talks on transactions tax
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Time not right for public registers of beneficial ownership, says OECD tax chief
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OECD Council approves incorporation of BEPS amendments into the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (1)
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Partnership Attribution Rules in Debt-Equity Regs Will Be Fixed
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U.K. Was 'Difficult Friend' to BEPS Process, OECD Official Says
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BEPS Implementation Is the Hard Part, Tax Experts Tell MPs
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Business Coalition Presses Treasury Not to Rush New Rules
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OECD Tax Chief Urges U.K. Support for Tax, Profit Reporting
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Treasury Centers Presumed Guilty Under Proposed Debt-Equity Regs
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Treasury Could Delay Earnings-Stripping Rules to Year's End (1)
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GAAR comes into force in Poland
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Firms That Left U.S. Still Enjoy Perks
One companywas celebrated at a U.S. embassy. Some traveled theworldwith U.S. officials, promoting productswith the imprimatur of the American government despite moving their legal headquarters outside the U.S. and cutting their taxes. Still others continue to receive U.S. government contracts.
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Tax officials preview coming OECD guidance on profit splits, attribution of profits to PEs
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Promoting tax certainty on the agenda of the next G20 presidency
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Disregarded Entity Regs Could Lead to Large Penalties, PwC Says
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Active Financing Made Permanent, but Questions Remain
Paul J. Crispino is a principalwith Deloitte Tax LLP. In this report, Crispino discusses the history of the active financing exception of section 954(h) and some of the challenges in satisfying its provisions. He also suggestsways to modify the rules to accommodate modern business practices.
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Tax Analysts Exclusive: Conversations: Corwin Reflects on Debt-Equity Regs, His Time at IRS
In March Erik H. Corwin left the IRS,where he served as deputy chief counsel (technical) for over four years, to become a principal in KPMG LLP'swashington National Tax practice.
Corwin recently spokewith Tax Analysts' Amy S. Elliott about the requirements in the proposed section 385 debt-equity regulations (REG-108060-15 2016 TNT 65-11: IRS Proposed Regulations),why the proliferation of no-rules in the section 355 tax-free spinoff areawaswarranted, andwhether the IRS Office of Chief Counsel should have more autonomy.
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BEPS Takes Center Stage At US OECD Tax Conference
Hundreds of policymakers, business executives, and senior tax officials met at the OECD International Tax Conference to discuss the recommendations proposed under the base erosion and profit shifting (BEPS) project and their impact on trade and investment.
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Sanders joins Dems urging public country-by-country tax reporting for US multinationals
US Democratic presidential candidate Sen. Bernie Sanders (I-VT) and three Senate colleagues on June 8 urged the Obama administration to require public disclosure of country-by-country tax reports of large multinational companies.
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GAAR comes into force in Poland
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Taxation and responsible business conduct
The OECD hosted a global responsible business conduct forum following the release of the Guidelines for Multinational Enterprises,which recognised timely compliance in taxation as a key driver for a fairer international tax system.
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Australian Federal Budget: Proposals to impact foreign MNCs
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Sanders joins Dems urging public country-by-country tax reporting for US multinationals (1)
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Debt-Equity Regs Could Apply to Millions of Closely Held Corps
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Banks Should Quickly Weigh in on New International Rules: IRS
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News Analysis: Should the OECD Take Over the Tax World?
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Offshore Captive Insurance Companies Under BEPS Attack