2019

On March 5 the U.S. Treasury and the IRS issued proposed regulations under section 250 (REG-104464-18) that provide guidance for determining the amount of the deduction for foreign-derived intangible income. Importantly, the proposed regulations also identify the required documentation that taxpayers must have by the FDII filing date to secure their FDII deductions. For each sale of property and provision of service, documentation is required both as to the recipient as a foreign person and as to the foreign use of that property or service.

Ireland vowed to reform environmental taxes as part of a sweeping new plan to arrest the damaging effects of greenhouse gas emissions, but stopped short of a unilateral commitment to carbon neutrality by 2050.

While discussing President Trump's trade policy agenda, U.S. Trade Representative Robert Lighthizerwas confronted about the administration's liberal use of tariffs,which he said areworth some economic discomfort in the United States.

The three British Crown Dependencies - Jersey, Guernsey and the Isle of Man - said onwednesday theywould move to reveal publicly the true ownership of firms based in their jurisdictions, a changewelcomed by anti-corruption campaigners.

The Dutch government may reconsider plans to cut the country's corporate tax rate to 20.5 percent, Prime Minister Mark Rutte said on Tuesday.

Recent rules on the international provisions of 2017's tax law attempt to resolve gaps and contradictions in the legislation's framework for global intangible low-taxed income ÔøΩ and in doing so, raise questions aboutwhether they exceed regulatory authority.

Rocio Bermudez, tax global practices & transfer pricing senior manager at Repsol, spoke to ITR about her company's participation in the first pilot of the International Compliance Assurance Programme.

The Senate Foreign Relations Committeewill likely hold a hearing nextweek on bilateral tax treaties and act on them the followingweek, Chairman Jim Risch said June 12.

Medtronic Plc is once again headed to trialwith the IRS in a $1.4 billion case over the value of intellectual property it transferred offshore.

The government is exploring mechanisms to calculate tax responsibilities of giant technology companies, such as Google and Facebook, according to Finance Minister Sri Mulyani Indrawati.

India, the U.S., and other countrieswith hundreds of millions of consumers and large import markets could rake in a bigger share of multinational tax revenue under a plan to change global tax rules.

Matias Milet and Roger Smith, of Osler, Hoskin & Harcourt LLP highlightwhy multinational corporations should be aware of the changes announced in Canada's 2019 Budget.

The logistics of an OECD pilot program designed to assess international tax risks of large multinational companies could be difficult to handle as it grows to include twice as many participants said Doug O'Donnell, commissioner of the Internal Revenue Service's Large Business and International Division.

Dutch lawmakers are urging the government to direct a special committee to findways to ensure multinational companies pay their fair share of tax in the Netherlands.

The International Monetary Fund urgedworld leaders to reform international tax rules that allow companies to pay little or no tax by shifting their assets to low-tax jurisdictions.

Businesses use data analytics to target their online ads at likely customers. Now the IRS's Large Business and International Divisionwill use that tool to determinewhich large and complex corporate taxpayers to audit. Carina Federico and David Blair of Crowell & Moring explain how andwhy.

Indian Finance Minister Nirmala Sitharaman heard from industry representativeswho are urging corporate tax reforms in the full fiscal 2019-2020 budget.

The new R&D Tax Incentive is opening up opportunities for more businesses doing R&D in New Zealand. Anand Reddy, Jill Somerfield and Nadinewilliams of PwC New Zealand consider how to maximize the benefits for your business.

U.S. multinationals got a mixed bag of IRS guidance today on new international measures under the 2017 tax overhaul that includes a much-requested exclusion under a new category of foreign income and proposed anti-abuse rules thatwould restrict tax deductions related to foreign-source dividends.

New IRS anti-abuse regulations limit a tax break available under the 2017 tax law for certain dividends a U.S. company receives from a foreign company inwhich it owns shares. The IRS released the rules in temporary and final form June 14. The agency also released proposed regulations that cross-reference the temporary rules.

U.S. multinationals now have guidance on a 2017 tax law provision intended to ensure that companies pay at least a minimum amount of tax on overseas profits.

Ten European Union countries have agreed on a revenue-sharing plan for the bloc's proposed financial transaction tax thatwould reimburse the administrative costs of countries that have small stock markets and few large companies.

Pierre Moscovici, the EU's top tax official, said that tax policy is crucial in the European Commission's efforts to curb income inequity as it seeks to battle populism among its member countries.

The Trump administration is deep in talkswith 129 other countries on implementing a new standard for taxing digital companies, including Alphabet Inc.'s Google, Facebook Inc. and Amazon.com Inc.ÔøΩbut its heart lies elsewhere in the discussions.

Germany and Francewill push European Union finance ministers June 14 to rally around a financial transaction tax that could help fill a potential EU Brexit budget hole.

Dutch opposition lawmakers lambasted a senior finance official for dialing down a motion aimed at ensuring that multinational corporations are taxed more fairly in the Netherlands.

Robert Goulder critiques the Ninth Circuit's revised opinion in the Altera litigation,which breathes new life in the commensurate-with-income language of section 482.

Citing pressure from adverse EU case law, the Dutch government has opened a public consultation on amending or abolishing the country's tax consolidation regime to complywith the EU's freedom of establishment rules.

Treasury's new anti-abuse rule on the dividends received deduction that addresses a timing mismatch between the participation exemption regime and other international tax rules has teed itself up as a target of future taxpayer litigation.

The IRS and Treasury's change of approach in newly proposed regs navigating partnerships under the global intangible low-taxed income provision could result in significantly less income inclusions for some taxpayers.

The Treasury Department has narrowed the reach of a new tax aimed at technology and pharmaceutical companieswith overseas income,wiping out an unintended consequence of President Donald Trump's 2017 tax overhaul.

The New Zealand tax office is preparing to take aim at some of theworld's biggest tech giants,with Google, YouTube, Uber, Facebook and Instagram allwithin its sights. In consideringwhether to enact a new digital services tax, New Zealand is following the lead of numerous other countries. Simon Akozu and Zoe Barnes, of MinterEllisonRuddWatts, considerwhether it is the right time for New Zealand to follow suit.

Canada plans to hike taxes on stock options that top-paid executives receive from large companies. The changes proposed in draft legislationwould bring Canada's tax treatment of stock options more in linewith U.S. tax treatment of options and restore the tax break's focus on helping small companies, like start-ups.

France plans to scrap 1 billion euros (890.15 million pounds) of tax breaks for companies to help fund a pledged 5-billion-euro reduction in personal income taxes, Budget Minister Gerald Darmanin said on Sunday.

The European Union should allow Italy to cut tax and invest in the green economy to boost the country's economy, Deputy Prime Minister Luigi Di Maio said on Monday.

A group of 75 conservative organizations and leaders on Monday sent a letter to Congress expressing their opposition to a carbon tax, pushing back at an idea that has received support from politicians and policy experts on both sides of the aisle as away to combat climate change.

A group of national security specialists urged a U.S. House of Representatives committee Monday to adopt legislation thatwould target shell companies, citing a report that says the anonymous ownership of businesses can facilitate tax evasion and other crimes.

U.S. corporate balance sheets continue to feel the impact of the 2017 U.S. tax overhaul, as companies pivot their capital allocation strategies in response to the new law. Companies funneled record amounts of cash to stock buybacks, dividends, capital spending and acquisitions last year. As a result, U.S. corporate cash holdings fell to a three-year low of $1.685 trillion in 2018, according to a report from Moody's Investors Service Inc.

Britain's next Prime Ministerwill have the dual challenge of leaving the European Union and setting up the newly independent country for economic success. So it's a good sign that some top contenders for the Conservative Party leadershipÔøΩthewinnerwill replace Theresa MayÔøΩstartedwith tax reform as campaigning began on Monday.

Alexandra Readhead investigateswhether IMF and OECD proposals on how to tax the digital economy, apply formulary apportionment, shift taxing rights and address profit shifting could apply to the natural resources sector. Alternatively, could source-based taxation improvements hold the answer?

As G20 countries ratify the OECD'swork on taxing the digital economy, tax executives expressed their concerns to International Tax Review that the body has not moved beyond proposals that they find problematic.

The European Parliament is expected to continue to push progressive legislation on tax matters following an election last month that saw eroded support for centrist parties. In recent years the Parliament has advocated laws requiring big corporations to publish their tax affairs and has voted for a common corporate tax base in Europe. It has also expressed support for taxing large digital corporations and pushed for laws that require tax advisers to disclose more of their activities to authorities.

Some US taxpayers are considering inversions because they fear negative tax implications if the Democrats gain control of the presidency and Congress in the 2020 elections and raise tax rate.

Whilewe'rewaiting for the big Tax Cuts and Jobs Act regulations on June 22, section 956 is still in the law, so there are final section 956 regulations to think about. To recapitulate, global intangible low-taxed income and section 245A regulations are expected by June 22. The GILTI ruleswill be accompanied by a notice of proposed rulemaking, the scope ofwhich is unclear, according to Raymond Stahl, senior counsel, IRS Office of Associate Chief Counsel (International). Practitioners are particularly concerned about the effective date of the section 245A rules, because companies made interim distributions that they hopewill qualify for the dividends received deduction (DRD).