2016

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.

by Ryan Finley

Treasury and the IRS areworking toward a solution to the "gap year" problem by allowing optional country-by-country reporting for 2016, but U.S. multinationals can help their own cause by engaging more in the global debate over corporate tax avoidance, according to Robert Stack, Treasury deputy assistant secretary (international tax affairs).

A forthcoming corporate integration plan is showing signs that its current designwill raise revenue, but Senate Finance Committee Chair Orrin G. Hatch, R-Utah, said April 21 that hewants the final outcome to be revenue neutral.

For the TNT story, go here. (subcription required)

Tax reform proposalswon't fix our broken corporate tax system. Most proposals suggestwe lower the rates and broaden the base by removing tax expenditures and the interest deduction. Those proposals have merit and seem attractive, but they fail to fix the unfairness of domestic companies paying more tax than multinational enterprises in identical circumstances. This article examines two reform options outlined by Edward D. Kleinbard.

For the Tax Notes viewpoint, go here. (subscription required)

In this article, Daniel Falk demonstrates that the requirements of the comparable uncontrolled transaction method regulations are virtually impossible to meetwhen strictly applied, and he discusses potential solutions to the problem.

For the Tax Notes viewpoint, go here. (subscription required)

Houseways and Means Tax Policy Subcommittee Chair Charlesw. Boustany Jr., R-La., said April 19 that hewill be meeting thisweekwith Republican committee members in order to seek clarity over how to proceedwith international tax reform.

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Practitioners on April 26 debated the viability of cash pooling arrangements following the issuance of new proposed regulations thatwould recharacterize some related-party debt as equity.

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TheU.S. governmentchalked up a big victory this monthwhen it stopped pharmaceutical giantPfizer Inc. from mergingwithAllergan PLCand shifting its address overseas to avoid U.S. taxes.

But there is at least one thing the Treasury Department still can't do: force Pfizer to book taxes on $80 billion in foreign profits the New York-based company has socked away overseas.

For thewall Street Journal story, go here.

On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project.

The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily of recommendations for significant policy changes that affect fundamental elements of the framework used by OECD member countries to tax international activities.

These recommendations are designed to be implemented as changes to domestic law aswell as through treaty provisions. The OECD has an expectation that the suggested ruleswill be "implemented accordingly" by the countries that participated in the BEPS project.

For the Financial Executives Institute report, go here.On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project.

The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily of recommendations for significant policy changes that affect fundamental elements of the framework used by OECD member countries to tax international activities.

These recommendations are designed to be implemented as changes to domestic law aswell as through treaty provisions. The OECD has an expectation that the suggested ruleswill be "implemented accordingly" by the countries that participated in the BEPS project.

For the Financial Executives Institute report, go here.

Diana Furchtgott-Roth compares a United States-based multinational and a foreign-based multinational investing $100 billion inwisconsin. She argues that the American tax system is biased against the United States-based multinational because it has to pay $35 billion in tax to bring $100 billion home from overseas,while the foreign multinational does not have to pay to invest in the United States.

This comparison is misleading at best.

For the New York Times letter, go here.

China's biggest tax overhaul in more than two decades starts May 1,with changes set to reduce the burden on services companies and encourage factories to upgrade and innovate.

For the DTR story, go here. (subscription required)

The Nigerian Tax Appeal Tribunal (Lagos TAT) on February 12 2016, in Vodacom Business Nigeria Ltd v. Federal Inland Revenue Service (FIRS), held that a Nigerian company that receives broadband services from a non-resident company must account for and pay value added tax (VAT) on those services. The TAT also held that because the non-resident company that provided the servicewas not bound by the VAT Act, the Nigerian company that received the service must self-charge and remit the VAT.

For the PwC Insight, go here.