2016

by PwC

The U.S. Competent Authority (USCA) office, on April 27, 2016, released statistics on cases addressed under the mutual agreement procedures (MAP) for calendar year 2015 (Report), including the number of MAP cases submitted, the number of cases closed, completion time, and pending cases.

First-quarter corporate earnings season is drawing to a close on a sour note. Quarterly profits are down 7.1% from a year ago, according to the Thomson Reuters TRI +% consensus estimate. There are a lot of reasons for this: a shaky global economy, persistently slow GDP growth in the U.S. and China, and the free-fall in crude oil prices, to name a few.

But there's also a new culprit that's emerging as a particularly challenging earnings headwind for multinational corporations: tax.

For the Forbes article, gohere.

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.

For the ITR story, go here.

by Brookings Institution

Changes in the taxation of business income by our major trading partners are creating shockwaves in the United States. On Tuesday, May 3, the Urban-Brookings Tax Policy Center examined the implications of theseworldwide changes for tax reform in the U.S. The symposium is named for Donald C. Lubick,who served in senior tax policy positions in the government for over four decades, and honors his extraordinary record of public service on behalf of better tax policy.

For the video of the conference, gohere.

Multinationals are facing a tougher tax environment, and it's coming atthem from a number of different angles.

For the Credit Suisse release, go here.

If Republicans reallywant business tax reform, they need to get out of their bubble and face the political reality. In the short term, they should consider drafting small-scale tax reform legislation that Clinton can sign. But it isn't just Republicanswho need a new mind-set. If Democrats reallywant to help Americanworkers, they need to get out of their own bubble and face the economic reality.

For the Tax Notes article, gohere. (subscription required)

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.

As tax authorities around theworld start to examine how e-commence sales affect their revenue from indirect tax it is important for taxpayers to knowwhat measures are being enforced.

For the ITR story, go here.

The Advance Pricing Agreements or transfer pricing rulings granted to U.S. multinationals by Ireland, the Netherlands, and Luxembourgwere principally designed to achieve U.S. tax deferral and not EU tax avoidance. Adverse BEPS effectswithin the European Unionwould be immaterial in comparison to the deferral of U.S. tax on residual IP related profits, andwould have occurred primarily in countries other than those chargedwith the granting of unlawful State aid. The significant tax policy implications for both Europe and the United States resulting from the State aid decisions by the EU Commission are explored here in detail.

by PwC

The Gabonese Republic has enacted the Finance Act 2016,which amends certain provisions of the Gabonese Republic Tax Code.

This Insight discusses the main changes resulting from enactment of the Finance Act 2016 that could affect multinational companies doing business in Gabon.

For the PwC Insight, gohere.

The fight for fair taxation in the EU is high on Parliament's agenda following the revelations as a result of LuxLeaks and the Panama papers. At a timewhen EU countries are struggling to recover from the crisis, MEPs are pushing for greater transparency and an end to tax unfair practices. Read on for our overview of Parliament initiatives.

For the European Parliament release, go here.

EU and non-EU parliamentarians convened on May 2 at the OECD in Paris,where theywere briefed on the current state of play on base erosion and profit-shifting project implementation, andwere able to compare notes on their respective countries' experienceswith BEPS measures, attendees told Tax Analysts.

If you are looking for an example of how corporate interests continue to dominate the agenda in Congress, a recent hearing on business tax reform held by the Senate Finance Committee is Exhibit A.

For the Tax Justice Blog post, gohere.

Thomson Reuters Checkpoint has just released a special report addressing the European Commission's Anti-Tax Avoidance Package (ATA) and other global Country-by-Country Reporting (CbCR) developments designed in conformitywith the OECD BEPS Action 13 recommendations. The report,

BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting,will help multinational enterprises (MNEs) gauge their readiness to collect and aggregate the data required under CbCR andwill equip themwith the latest CbCR information to navigate this complex, quickly evolving landscape.

For the report, go here.

While the Obama administration touts its recent rules to limit corporate inversions as a step forward towards fixing our broken tax code, it is clear this administration fundamentally misunderstands the problems that are driving American companies abroad. In the long run, punitive Treasury Department regulationswill only make America less competitivewhile this administration ignores the core problem: a hopelessly outdated corporate tax code.

For theweekly Standard article, go here.