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Lawmakers Looking to Dial Back Treasury Debt-Equity Rules
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Senate Finance Democrats Working on Anti-Inversion Package
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U.S. Multinationals Hurt by Debt-Equity Rules, Businesses Say
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The OECD/G20 BEPS recommendations: boosting U.S. tax reform
Most American policymakers believe the U.S. corporate tax system needs reforming – and the facts back up their view This system is bad for domestic job creation, penalizes the entire U.S. economy, and needs to be fixed urgently.
Despitewidespread agreement about these deficiencies, the push for U.S. corporate tax reform has been all talk,with no action for 30 years. But now, a project that had caused much consternation in American tax policy circles may offer away forward for this vital effort.
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Debt-Equity Rules Could Include Brother-Sister Corporations
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New IRS LB&I Campaigns Approved With More Under Evaluation
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Inbound Distributors Target of IRS Transfer Pricing Campaign
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EU Official Conditionally Endorses OECD Guidelines
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Working Party 6 Expecting More PEs as a Result of BEPS
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Legislation on Discouraging Inversions Expected Soon
The Senate Finance Committee and the Joint Committee on Taxation areworking together onways to decrease incentives for corporate inversions, and expect to produce legislation later this summer.
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European Commission State Aid 'Mess' No Closer to Resolution
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Cross-Border Partnership Transfer Rules Liberalization Possible
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Parliament calls for crackdown on corporate tax avoidance
The EU Commission proposal for an EU anti-tax avoidance directivewaswelcomed by Parliament in a resolution voted onwednesday. MEPs nonetheless advocated stricter limits on deductions for interest payments and tougher rules on foreign income. They also called for more transparency for trust funds and foundations, common rules for "patent box" tax reductions on intellectual property earnings, and an EU blacklist of tax havens and sanctions against uncooperative jurisdictions.
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Guiding Principles for Tax Reform
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Countries May Get Together on Company Financial Reports: IRS
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IRS Considering Extra Time to Amend Country Reports in 2016
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IRS Creating New Age of Uncertainty, Tax Litigators Say
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Transfer Pricing Enforcement Views Entire Landscape': IRS
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People Missed Point of BEPS Transfer Pricing Report, Bello Says
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LB&I's First Audit Campaigns to Be Announced Soon
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India introduces new equalization levey on online advertising revenue
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U.K. Treaty Conflict: Unintended (?) Consequences of the U.S. Debt-Equity Regulations
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Country-by-Country Reporting May Help Resolve Tax Disputes
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Explosion' of Double-Tax Cases Growing, IRS Official Says
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CbC Regs on Schedule as Work on Optional Filing Continues
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Mazur Still Aiming to Finalize Debt-Equity Regs This Year
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U.S. Seeking Certainty' in New Permanent Establishment Rules
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Treasury Official Dismisses Hatch's Corporate Integration Idea
Corporate integration doesn't seem to offer the right policy prescription to address cross-border tax problems, a Treasury Department official said.
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No Discussion Draft Expected for OECD Multilateral Treaty Tool
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U.S. May Give Multinationals Option to Report Data Early
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BEPS Report on Transfer Pricing 'Could Have Been Worse'
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India releases draft rules on computation of income attributable to indirect transfer of assets
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Fixed Ratio Rule Could Make U.S. Debt-Equity Regs Unnecessary
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U.S. Waiting for OECD's Profit Attribution Rules
Realistically, it is unlikely that the United Stateswould sign the permanent establishment provision of the OECD's multilateral instrument (MLI).
The U.S. is participating in the development of the OECD's multilateral instrument (MLI) to implement the treaty-related measures of the base erosion and profit-shifting project, but iswaiting to see the finished product before decidingwhether to sign the MLI, said Quyen Huynh, Treasury associate international tax counsel.
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U.S. Tax Review (1) (3)
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News Analysis: How BEPS Brought on the State Aid Investigations
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Vestager: EU Must Take Action Against Unrealistic Tax Deals
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Short Timeline for Earnings-Stripping Rules Is a Concern
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Claiming the Indirect Credit for Foreign Taxes of a PFIC
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Treasury Could Modify E&P Exception to Debt-Equity Rules
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International Tax News Edition 40 June 2016
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The key to stopping inversions is tax reform, not political rhetoric
Politicians continue to rail against corporate inversions at every opportunity. Presidential candidates repeatedly have called for a government crackdown to prevent businesses from moving overseas. Unfortunately, most of their populist rhetoric misses the mark.
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Proposed Section 385 Regulations and S Corporations: Borrower Beware!
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The Increasing Relevance of Transfer Pricing in M&A
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Section 367 Adrift: Old Statute, New Applications, Part 2
by Peter M. Daub
The first partof this two-part report showed that, beginningwith its original enactment in 1932 and through the 1980s,when the statute effectively took its current form, Congress, the courts, and the IRS understood section 367 to apply onlywhen the unmodified application of a subchapter C provision specified in section 367 to a cross-border or foreign-to-foreign transactionwould thwart a basic tax policy or provision other than one reflected in a specified provision.This part of the report shows how the IRS has began to pursue other goals such as subjecting to U.S. income tax funds or other property transferred from a foreign subsidiary to its U.S. parent, even if the property does not represent income or gain in any conventional sense, and expanding the reach of U.S. taxing jurisdiction over income earned by foreign subsidiaries that has not been repatriated.
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EU Competition Arm to Stick to OECD Transfer Pricing Guidelines
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In Transfer Pricing, Control' Defined By Power, Not Ownership
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Proposal for a New Institutional Framework for Mandatory Dispute Resolution
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Video: Exclusive interview with Pascal Saint-Amans (1)
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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EU Financial-Transaction Tax Push May Soon Grind to a Halt
The European Union's plan to implement a financial-transaction tax may be called off soon if more countries back out, Austrian Finance Minister Hans Joerg Schelling said.