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U.S. Competent Authority statistics for 2015 reflect the global controversy environment and the growing need for relief from double taxation
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.
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Profit shifting and U.S. corporate tax policy reform
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U.S. companies are saving $100 billion a year by shifting profits overseas, report says
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The New U.S. Model Treaty Is Out!
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Is Tax Playing A Role In Weak Corporate Earnings?
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.
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BEPS Brings on Information Overload, IRS Official
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Expanded Group Definition in Debt/Equity Regs May Be Narrowed
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Pain of Earnings-Stripping Rules Might Ease: Treasury
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American Business Competitiveness Act: Good Steps Toward Business Tax Reform
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Obama's Wall Is Bad Too
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Tax Writers Continue Examining Tax Reform Proposals as Administration and Regulators Focus on International Issues - See more at: http://www.natlawreview.com/article/tax-writers-continue examining tax
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PE changes increase risk of tax exposure in jurisdictions where a company has no legal entity (1)
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.
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No More Hiding in U.S. Disregarded Entities Under IRS Rules
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Patent Box Meeting OECD Rules Likely OK for U.S Model Treaty
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Final Country-by-Country Rules May Address Territories
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Debt-Equity Regs May Change Current Law
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U.S. Model Treaty Emphasizes Antiavoidance Measures
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News Analysis: A New Protectionism in U.S. Tax Policy?
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U.S. Tax Review (1) (4)
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How foreign tax changes affect U.S. businesses and the prospects for tax reform
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.
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Profit Shifting Under Pressure
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.
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States May Follow Treasury's Lead on Debt-Equity Rules
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Related-Party Debt Rules Could Clarify Partnership Lending
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300 economists urge leaders to reject tax havens
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Economic Analysis: For Economy's Sake, Time for Tax Reform Compromise
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)
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U.S. Taking Cautious Approach to Adoption of New PE Standard
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IRS Related-Party Debt Rules to Increase States' Focus on Transfer Pricing
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No 'Legitimate Expectations' in Excess Profit State Aid Case, Commission Says
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U.S. Inversion Rules Expected to Affect Canadian Companies
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Belgian Minister: EU Demand for Tax Repayments Stupid
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PE changes increase risk of tax exposure in jurisdictions where a company has no legal entity (2)
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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New IRS Intangibles Rules Called Radical Policy Departure
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Companies Need to Step Into Global Tax Debate: U.S. Official
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Stack Says Tax Reform Agenda Should Address International Issues
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EU Mulling Fair Taxpayer' Label, Better Dispute Resolution
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Delete Expenditures in Reshaping Tax Code: Harvard Professor
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Introduction to Capital Formation 101
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Tax authorities adapt to rise of e-commerce
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.
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The Intersection of EU State Aid and U.S. Tax Deferral: A Spectacle of Fireworks, Smoke, and Mirrors
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.
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Gabon corporate tax amendments enacted
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.
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After Altera, Services Regs May Be Next
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Overview: the European Parliament's work on taxation
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.
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Investment Into U.S. Fueled by Tax-Driven M&As, Report Says
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Investment Into U.S. Fueled by Tax-Driven M&As, Report Says (1)
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News Analysis: Who's Afraid of Anti-Inversion Rules?
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Parliamentarians Compare BEPS Project Notes at OECD Meeting
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.
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The Huge Disconnect Between Congress and the Public on Business Tax Reform
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Thomson Reuters Releases Special Report on OECD''s Country-by-Country Reporting Requirements
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.
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We Need a Serious Approach to International Tax Reform
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.