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2018

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New EU Beneficial Ownership Rules Enter Into Force

  • By Tax Analysts

The European Commission haswelcomed the entry into force of rules that give national tax authorities direct access to information on the beneficial owners of companies, trusts, and other entities from January 1.

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Indias Challenges With Intangible Taxation Before and After the GST


In this article, the authors discuss the taxation of intangibles in India, looking at the inconsistencies in the old indirect tax regime and examining how the recently enacted goods and services tax addresses transactions in intangibles, particularly intellectual property rights.

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German tax office targets Chinese online retailers: Handelsblatt

  • By Reuters Staff

The effort to get online retailers to pay their share of taxes has crossed the pond. German tax investigators on Thursday seized goods and accounts from Chinese retailers for failing to pay sales taxes on products they sold through Amazon. "A German taxpayers' union said in November that Germany could be losing out on 1 billion euros ($1.2 billion) annually because online retailers from China, or other non-EU states, fail to pay value added taxes of 19 percent, knowingly or not," Reuters reported.

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Mnuchin Objects to EU Council's Inclusion of U.S. Territories as 'Non-Cooperative'

  • By Tax Analysts

Treasury Secretary Steven Mnuchin, in a letter to the secretary-general of the Council of the European Union, has urged the council to reconsider its decision to subject non-EU jurisdictions to a separate review process and to release its own list of "non-cooperative jurisdictions" for tax purposes and has objected to the inclusion of American Samoa and Guam on that list.

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Tax Law Offers a Carrot to Gig Workers. But It May Have Costs


A provision in the new tax law allows sole proprietors ÔøΩ alongwith owners of partnerships or other so-called pass-through entities ÔøΩ to deduct 20 percent of their revenue from their taxable income. The tax savings,which could be around $15,000 per year for many affluent couples, may prove enticing toworkers. "If you're above the median but not at the very, very top, onewould think you'd be thinking it through," said David Kamin, a professor of tax law at New York University.

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Tax Reform and Interest Expense: Did Congress Get It Right?


The treatment under the former version of section 163(j) has long been viewed a culprit in earnings stripping. Comparatively speaking, it ranked among the more permissive interest barriers you'll encounterworldwide. Given the Byrd rule and its resulting need to limit revenue losses, interest expensewas never going to survive tax reformwithout significant tweaking. That'swherewe're at, although the journey involved some unexpected twists. This article examines the provisions of the tax reform bill, known informally as the Tax Cuts and Jobs Act (H.R. 1), dealingwith interest expense, including measures thatwere eliminated during conference negotiations.

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Lobbying on the BEPS Project? Assessing the Influence of Different Interest Groups


This paper studies lobbying on the OECD's BEPS Project by analyzing comment letters to determine the lobbying success of firms, the tax profession, and members of civil society. The authors find evidence that the tax profession and civil society are more influential at the conceptual level, but that at the technical level, atwhich details of a regulation are determined, the individual tax professionals are more successful than firms.

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Bulgarian Presidency Outlines EU Tax Plans


The "fair and efficient" taxation of corporate profits and the fight against tax avoidance and evasion through enhanced administrative cooperation are among the priorities of the new Bulgarian presidency of the European Union,which commenced on January 1, 2018.

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Saudi Arabia and UAE introduce 5% VAT in bid to narrow deficits


Saudi Arabia and the United Arab Emirates have imposed value added tax as the largest Gulf economies seek to boost non-oil income and narrowwide fiscal deficits caused by years of low oil prices.

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Fed board unsure of economic boost from Trump tax cuts


Federal Reserve board memberswrestledwith how much of an economic impact to expect from Donald Trump's tax cuts as they raised rates last month and continued to be flummoxed by persistent low inflation, according to minutes released onwednesday.

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IRS Notice addresses the 'Toll Tax' under amended Section 965

  • By PwC

The IRS and Treasury issued Notice 2018-07 (the Notice) on December 29, 2017, providing preliminary administrative guidance and indicating plans to issue regulations relating to the 'toll tax' due upon the mandatory deemed repatriation of certain deferred foreign earnings.The Notice provides guidance for determining aggregate foreign cash positions and accumulated post-1986 deferred foreign income (tested earnings and profits). The Notice also indicates future guidancewill be released addressing the application of stock basis adjustments from previously taxed income distributions, the treatment of affiliated groups for purposes of making a consolidated return, and the impact of certain foreign currency gains or losses recognized on distributions as a result of Section 965's imposition.

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Argentinian Budget Overhauls Corporate Tax System


Argentina intends to reduce its corporate tax rate by 10 percent by 2020.
The planswere confirmed in the 2018 Budget,whichwas signed off by the Senate on December 27, 2017, and enacted on December 29.

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Will US tax reform spark a new 'race to the bottom'?


The US's long-awaited tax reform has brought the country's corporate tax rate down to 21% - below 2017's OECD average rate of around 25%.will this spark a newwave of tax competition?

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