2018

HM Treasury has issued a brief regarding the 2 percent tax on the revenues of specific digital businesseswhose revenues are linked to the participation of U.K. users; the taxwill take effect April 2020 barring a globally agreed solution on digital economy taxation.

The American Bar Association Section of Taxation has requested changes to proposed transition tax regulations (REG-104226-18), focusing its comments on passthrough entities and individuals (but not S corporations), the netting of accumulated post-1986 deferred foreign incomewith deficits in other related entities, and the foreign tax credit.

Although Brazilians have elected a new president, some practitioners and analysts say it's not clearwhether the country's controversial new leader can deliver on his ambitious tax plans, or evenwhat his specific plans are.

The government of the Netherlands has launched a six-week consultation on legislation targeting hybrid mismatches ÔøΩ including the infamous Dutch CV/BV structure ÔøΩ in linewith the EU's second anti-tax-avoidance directive.

A new report estimates that five U.S. multinational technology companies avoided a combined £5 billion in U.K. tax over the last several years, but at least one commentator says the report's conclusions are dubious.

EU member states in favor of the European Commission's proposal for a digital services tax (DST) are trying to demonstrate that the taxwould not fallwithin the scope of member states' tax treaties.

The U.K. moved on Monday to extract more tax from the likes of Google and Facebook, even as London pushes aggressively to make itself aswelcoming as possible to the tech industry as the country prepares to leave the European Union next year.

The U.K. government plans on introducing a new digital services tax (DST) in April 2020 ÔøΩ butwould consider dropping the tax if a globally agreed solution on digital economy taxation emerges from the OECD's discussions.

Ever since the Tax Cuts and Jobs Act introduced the term "foreign-derived intangible income" (FDII) into the popular tax lexicon, there's been some disagreement about how to pronounce the acronym ÔøΩ so much so that even the national media took note.

Colombiawill seek to raise income tax on high earners and lower duties on businesses, among other tax measures, to raise 14 trillion pesos ($4.4 billion) to finance next year's budget, the head of the DIAN tax agency said on Monday.

The U.K. said itwill move aheadwith plans to introduce a first-of-its-kind tax on locally generated revenue by large technology firmsÔøΩthe most concrete attempt yet by an industrialized nation to rewrite theworld's tax code for the digital era.

Among all the measures announced in U.K. Budget 2018, perhaps the most significantwas the one the Chancellor did not mention - the U.K. corporation tax ratewill fall from 19 percent to 17 percent in 2020. Many people thought this cut could be delayed or reversed, but nothingwas said and so itwill go ahead as planned.

Shares of U.S. automakers rose on Monday after a report that Chinawas considering halving its car purchase tax to 5 percent to support its struggling auto industry,which has been hit hard by the ongoing Sino-U.S. tradewar.

Britainwill levy a new tax on thosewho make or import plastic packagingwith less than 30 percent recycled material, finance minister Philip Hammond said on Monday.

Britain's Treasury chief unveiled Monday a new tax on big internet companies' revenues, insisting it is time that the global tech giantswith profitable business in the U.K. pay their fair share for public services.

British Chancellor of the Exchequer Philip Hammond is likely to give a 900 million pound ($1.15 billion) tax cut to small high-street retailers in his annual budget on Monday to help them compete against online competition, the government said late on Friday.

A majority of euro zone countries favour the single currency area adopting a fiscal capacity, or common budget, French Finance Minister Bruno Le Maire said on Friday. After meeting German Finance Minister Olaf Scholz in Berlin, Le Maire said they had also made progress towards achieving a compromise position on plans for a digital services tax.

Dozens of countries are stepping up efforts to levy new taxes on technology giants such as Alphabet Inc. and Facebook Inc., hoping to capture revenue from digital services as economic activity increasingly shifts online. Inspired by European Union proposals to impose a tax based on the revenue of tech companies rather than their profit, South Korea, India and at least seven other Asian-Pacific countries are exploring new taxes. Mexico, Chile and other Latin American countries too are contemplating new taxes aimed at boosting receipts from foreign tech firms.

The government of the U.K. island dependency of Jersey, responding to a European Union crackdown against offshore tax havens, has filed draft legislation to require local companies to show they're engaged in matters of "adequate economic substance."

Tech sector groups urged Chancellor of the Exchequer Philip Hammond to avoid unilateral taxation of the digital economy in his budget announcement,warning that itwould damage competitiveness and the United Kingdom's reputation.

The new focus on control of risk in OECD transfer pricing guidance is prompting the U.S. competent authority and its foreign counterparts to reassess old approacheswhen considering advance pricing agreement renewals.

On October 16 the OECD used the latest installment of its Tax Talkswebcast to provide an update on developing a solution for taxing the digital economy. The organization is under pressure to meet a 2020 deadline for the G-20 but also to show meaningful improvements in 2019, and during thewebcast, it reported progress.

A year ago,we told readers to forget everything they had ever learned about international tax planning. Five months ago,we made predictions for the U.S. midterm elections.we stand by both.

The economic impact of special financial institutions, or SFIs or letterbox companies, on the Dutch economy "seems to be limited," the Dutch central bank said in a statement.

An Australian anti-tax avoidance task force collected more than A$2.8 billion ($1.9 billion) in 2017-18,with nearly half of that amount coming from multinational companies.

Confidentialworking papers from the European Union indicate the bloc's lawmakers are consideringways towind down its controversial 3 percent digital tax. The strategy could allay fears from countrieswhoworry the proposal could become permanent. The logicwas laid out in a document obtained by Bloomberg News, dated Oct. 22 and prepared in advance of a November meeting of the bloc's finance ministers.

Multinationals need to provide all documents related to global tax disputes to both governments involvedÔøΩor risk having their cases set back by six months, an IRS official John C. C. Hughes said.

EU member nations remain at loggerheads over the proposed 3 percent tax on digital companies, after a high-stakes meeting of the bloc's tax specialists.

A majority of euro zone countries favour the single currency area adopting a fiscal capacity, or common budget, French Finance Minister Bruno Le Maire said on Friday. After meeting German Finance Minister Olaf Scholz in Berlin, Le Maire said they had also made progress towards achieving a compromise position on plans for a digital services tax.

Karen Sowell of the New York State Bar Association Tax Section has submitted a report on the new section 245A dividends received deduction for dividends distributed by a controlled foreign corporation

In this article, the authors discuss China's post-BEPS international tax landscape.

After a federal oversight board rewrote Puerto Rico's five-year fiscal plan, the island's government said itwill challenge the decision by amending its court appeal of the board's earlier rejection of the 2019 budget.

U.S. Treasury Secretary Steven Mnuchin issued a freshwarning against the EU's digital services tax (DST) proposal, urging countries against unilateralism on digital economy taxation and to engage at the OECD to find answers instead.

The Australian Taxation Office has issued practical compliance guidelines regarding the application of retroactive anti-hybrid legislation currently pending in Parliament to arrangements that have been restructured by taxpayers to avoid hybrid mismatch classification.

Anticipating that taxpayers maywant to restructure their hybrid arrangements to avoid triggering hybrid mismatch rules that take effect next year, the Australian Taxation Office (ATO) has released a new practical compliance guideline.

Proposed business interest deduction regulations have arrived at the Office of Management and Budget for review, suggesting that guidance could be imminent on definitions, computations, and consolidated group rules,while partnership rules appear scheduled for later.

In this article, the authors analyze the EU's new administrative cooperation directive, provide guidance onwhen a specific arrangement is reportable, and consider the effects on alternative investments made from Luxembourg.

In this article, the authors discuss the EU's proposals for taxing the digital economy,with a focus on the proposed directive for a short-term digital services tax.

The Spanish government has launched a consultation for a digital services tax (DST) similar to a controversial levy being considered by the EU.

The Jersey government has lodged draft legislation imposing local economic substance requirements on resident companies as part of its effort to address concerns cited by the EU Code of Conduct Group and the European Commission.

The U.N. tax committeewill kick off its taxation of the digital economyworkwith a questionnaire for its members and other stakeholders butwill start drafting a reportwithoutwaiting for resultswherever possible.

Both Apple and Dublin are appealing the 2016 multibillion-euro tax ruling, and the company refutes allegations that it shirks its obligations, claiming it's theworld's largest corporate taxpayer. Still, the European Union is not slowing down,with officials now haggling over new digital tax proposals thatwould force many of Silicon Valley's biggest names to fork over an even greater slice of their revenue generated inside the 28-member bloc.

In an October report on socialist policies, the Council of Economic Advisers found that U.S. taxation is considerably more progressive than the taxation of Nordic countries because low- and middle-income taxpayers face higher average tax rates in Nordic countries than in the United States and Nordic nations rely more heavily on regressive value-added taxes.

The OECD and the Inter-American Center of Tax Administrations (CIAT) areworking together "to promote a common understanding of the impact of [base erosion and profit shifting] measures developed under the OECD/G20 BEPS Project," including their joint hosting of an event in Lisbon, Portugal.

The Association of International Certified Professional Accountants has issued a policy paper calling for international coordination to address "taxation concerns raised by digital transactions and the general digitalization of the economy."

"International tax issues and tax policies are most effective and efficientwhen tax systems operatewithin an internationally agreed upon platform and approach," the Association of International Certified Professional Accountants saidwhile announcing the release of a report regarding digital economy taxation.

In this article, the author considers how U.S. shareholders receiving deemed distributions from treaty countries could be affected by recently proposed Treasury regulations on the section 965 transition tax and the section 951A global intangible low-taxed income tax.

Canadian Prime Minister Justin Trudeau announced that the federal carbon pricing backup plan for provinces and territories that do not enact their own emissions regimes by 2019will return carbon tax proceeds to residents.

Members of the European Parliament endorsed changes to the digital services tax proposal thatwould alter the definition of "significant digital presence" and raise the tax rate from 3 to 5 percent.