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US group urges Congress to cut OECD funding, claims US harmed by BEPS international tax standards
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Is a U.S. Patent Box a Good Idea?
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Related-Party Debt Not a Rose: IRS Rules Could Make It Stock
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Endangered Species: The U.S.-Based Multinational
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The Ineluctable Logic of Adopting an IP Box Tax Regime
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Debt-Equity Rules Harmful, Overbroad, Tax Attorney Tells IRS
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Fewer Shareholders Pay U.S. Taxes on Dividends
A new study showing that a shrinking fraction of shareholders of U.S. corporations pay taxes on dividends is bolstering a drive to revamp the corporate tax system.
The specter of double taxation,which animates complaints about today's U.S. corporate tax code, is receding, according to a new study from the Tax Policy Center.
For thewall Street Journal story, gohere.
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China targets multinationals that shift profits among countries
China is planning to require multinationals to disclose more detailed information about their overseas affiliates as part of an international effort against tax evasion.
The proposalwould make it more difficult for large companies to avoid taxes by shifting profits among different countries, thewall Street Journal reports, citing tax consultants.
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Partnership Debt Subject to Earnings-Stripping Rules: Treasury
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Cash Pools May Get Documentation Break in Debt-Equity Rules
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Hong Kong's 16.5 Percent Rate Helps Region Attract U.S. IP
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Treasury Official: Model Treaty Guidance Due This Summer
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Study: Australian Corporate Tax Cut to Benefit U.S. Most
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Debt/Equity Regs May Encourage Foreign Buyout of U.S. Businesses
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New U.S. Model Treaty Evolved From Negotiations
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Levin Introduces Bill to Target Hopscotch Lending, Decontrolling
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Countries targeted US companies in BEPS project to increase tax revenue, US Treasury official charges
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New Model Treaty Seeks Factual Connection' for Activities
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Another (Critical) Look at the Inversion Excise Tax
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Anti-Inversion, Anti-Expatriation, and the Abandonment of Principle
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Tax Chiefs Push Ahead With CbC and CRS Data Exchange System
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Revised India and Mauritius treaty ends decade-long tax debate
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Integration of Corporate and Shareholder Taxes
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CbC Reporting Remains Of Concern For US: Boustany
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Integrating the Corporate and Individual Tax Systems: The Dividends Paid Deduction Considered
The Senate Finance Committee on May 17 held a hearing on corporate tax integration.
For the member andwitness statements from the hearing, go here.
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The Inadequacy Of BEPS To Fix What's Wrong With The Corporate Income Tax
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Coalition For Tax Competition Letter Urges Congress to Defund the OECD, Oppose BEPS
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U.S. Using BEPS Project to Safeguard Tax Base, Stack Says
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Lew Calls for Congress to Strengthen Tax Information Sharing
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Economic Analysis: Trending Ideas That Could Shape Future Tax Policy
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U.S. Official: Unilateral Measures Violate Spirit of BEPS
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Tough Cash Pool Decisions Ahead Under Debt-Equity Rules
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India and Mauritius treaty protocol introduces source-based taxation of shares
The governments of India and Mauritius signed a protocol amending the countries' tax treaty on May 10, 2016.
Key features of the protocol include the introduction of source-based taxation of capital gains on the transfer of Indian companies' shares acquired on or after April 1, 2017, and source-based taxation of interest income of Mauritian banks and fees for technical services.
For the PwC Insight, gohere.
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U.S. Groups Argue Against Earnings-Stripping Rules
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Heads of tax administrations take big step forward in global tax co-operation
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European Parliament Approves Country-by-Country Reporting
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Quit Bullying, Fight Corruption in U.S., Tax Havens Say
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Officials Defend Distribution Rule in Anti-Inversion Regs
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Coalition Renews Push to Cut U.S. Funding for OECD
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IRS Advises Agents on Taxpayer Use of Section 482
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Give Us More Time on Debt-Equity Rules, Groups Ask Treasury
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Tax Treaty Break From Inversions Rules Possible: Treasury
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Debt-Equity Bifurcation Could Expand Beyond Related Parties
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European Green Party: U.S. Should Be On Tax Haven List
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Report Calls U.S. Multinationals' Tax Disadvantage Exaggerated
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A new boost to transparency in international tax matters: 6 new countries sign agreement enabling automatic sharing of country-by-country reporting
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The Necessary and Valuable Economic Role of Tax Havens
Simply stated,when politicians have toworry that jobs and investment can cross borders, they are less likely to impose higher tax rates and punitive levels of double taxation. Interestingly, even the statist bureaucrats at the Organization for Economic Cooperation and Development agreewith me,writing that tax havens "may hamper the application of progressive tax rates." They think that's a bad thing, of course, butwe both agree that tax competition means lower rates.
So Iwas very surprised to see some economists signed a letter saying that so-called tax havens "serve no useful economic purpose."
For the Cato article, gohere.
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If Everyone Is a Tax Haven, No One Is
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PE changes increase risk of tax exposure in jurisdictions where a company has no legal entity
Multinational enterprises (MNEs) are facing new challenges arising from OECD's developments regarding the determination of a taxable presence in a foreign countrywhere the company operateswithout a legal entity.
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Section 385 proposed regulations would vitiate internal cash management operations
by PwC
On April 4, 2016, Treasury and the IRS proposed regulations under section 385. The Proposed Regulations appear to be intended to limit the effectiveness of certain tax planning techniques by recharacterizing certain related-party financings as equity, evenwhere the financing is in the form of straight debt instruments.
For the PwC Insight, gohere.