2019

The Public Sector Pension Investment Board, following up on prior comments, has asked that the base erosion antiabuse tax regulations provide an exception to the BEAT aggregation rule so that organizations that lack private shareholderswill be treated as other than corporations for purposes of applying the code's attribution and control tests.

A European Parliament groupwill be advocating for reforms set forth in a blueprint that takes aim at several tax policies and practices favoring large companies and high-wealth individuals.

While the tax burden onworkers remains high in Belgium, the country's political parties have been unable to reach a consensus on how to shift it to capital.

Targeting extra taxes on specific sectors such as foreign companies may be attractive but could be economically damaging, the IMF told the Czech Republic in an obliquewarning against its plans for a digital tax.

Strong public pressure for immediate action ÔøΩ particularly in Europe ÔøΩ to tax large digital companieswith significant local revenue has prompted the spread of unilateral tax measures that are politically popular but technically flawed.

Mauritius companies that have not yet started, or have ceased, operations and have not derived any income during a fiscal year must submit a declarationwithin three months from the end of that fiscal year.

The OECD is eyeing July to present key findings and next steps following the conclusion of a project examining Brazil's potential to align the country's transfer pricing regimewith global standards.

The U.S. Tax Cuts and Jobs Act could lead to long-term tax revenue losses of 7 percent of corporate income tax revenues in Luxembourg because it mayweaken multinationals' incentives to locate assets there, according to the IMF.

The decision towithdraw the temporary branch currency regulations on aggregate partnershipswhile finalizing only antiabuse rules suggests Treasury and the IRS have yet to decide on the right approach to a difficult issue.

Robert Goulder rethinks his initial opposition to a BEPS-influencedwithholding tax, as proposed by professors Yariv Brauner and Andrés Báez.

While IRS and Treasury Department officials share taxpayers' concerns regarding the complexity of the proposed regulations on previously taxed income, there are few obviousways to simplify an inherently complex area.

In a letter published on April 29, 2019, the United States National Foreign Trade Council urged the Senate to approve several pending double tax avoidance treaties. The letter, signed by more than 85 US companies, highlights the important role of income tax treaties in fostering bilateral trade relations and protecting US taxpayers from double taxation.

City leaders here are proposing to more than triple a tax on stock compensation in a bid to use revenue from awave of public offerings by tech companies to address concerns about growingwealth disparity. The so-called IPO taxwould raise the levy on corporations for stock-based compensation to 1.5% from the current rate of 0.38%. Thatwould restore the rate to its level in 2011when the city, pulling out of recession, cut it as part of a change in its tax structure intended to keep companies from leaving.

India's equalization levy on digital advertising revenuewill be repealed if countries settle on a new international tax framework for the digital economy, according to an Indian revenue official.

The administrability of rules on taxing the digital economywill be key to reaching international consensus on a long-term solution by the 2020 deadline, said Carol Doran Klein of the U.S. Council for International Business.

To protect its reputation, Ireland should continue to proactively participate in multilateral efforts to reform the international corporate tax rules, particularly the ongoing debate on taxing the digital economy, the IMF said.

U.S. Treasury officials have been engaged in "vigorous diplomacy" to dissuade countries from enacting unilateral measures ÔøΩ especially digital services taxes ÔøΩwhile countries are in the middle of negotiations on a global consensus-based solution.

Mindy Herzfeld questions the utility of the U.N. tax committee's efforts to provide its own solutions for taxing the digital economy, given that its membership is less exclusive than that of the OECD inclusive framework and its members act in individual, not representative, capacities.

Bavaria's Christian Social Union (CSU) has come out against a carbon tax as part of a German carbon pricing scheme, saying it prefers a reduction in energy taxes to spur environmental change.

A Swiss referendum on a tax reform package thatwould abolish cantonal tax regimes that the European Commission says favor multinationals over domestic companies is expected to pass May 18, according to a recent poll.

Ireland reported an 8 percent bump in net exchequer receipts for 2018, partly thanks to a double-digit increase in corporate tax receipts paid mostly by large multinationals, according to the Irish tax authority's latest results.

As governments continue debatingways to tax the digital economy, a top Google executive reiterated calls for simpler corporate tax rules, pledging that his companywill follow the new rules ÔøΩwhatever they may be.

In this article, the author discusses the Court of Justice of the European Union's recent judgment in N Luxembourg 1, addressing the abuse of exemptions contained in the interest and royalties directive.

An IRS official expanded on plans to introduce a new large corporate compliance program and said the agency now has a better estimate of taxpayers that should be treated as large, complicated organizations.

On April 4, 2019, Italy's government approved a Growth Decree designed to stimulate economic recovery aswell encourage foreign investment by offering foreign entities the same tax incentives available to Italian enterprises.

Tax directors are dealingwith more audits, but standardising global tax operations can greatly ease the burden because it helps tax authorities understand corporate tax positions better.

Chinawill extend preferential taxes for producers of integrated circuits and software companies, the cabinet said onwednesday. Chinawill attract more domestic and foreign investment into its information industry, the State Council, or cabinet, said after a regular meeting.

Tax professionals areworried about how to identify user participation accuratelywithin any digital business model, particularly given how easy it is for users to hide their true location.

As details emerge of digital taxes in the Czech Republic and Malaysia, corporates told ITR theywish countrieswould leave it to the OECD process - but they are fearful ofwhat might emerge from it.

UK authorities are stepping up investigations into the tax affairs of US multinationals,which account for a growing share of suspected underpayment by large businesses.

Lance Cunningham and Meera Pillai, of BDO Australia, discuss the tax measures recently announced by the Australian government in its Federal Budget: they highlight action points that overseas taxpayers transacting, investing in, tradingwith and selling to Australia, should be considering.

Most countries are opting out of adopting new OECD standards aimed at shutting down a favorite tax planning maneuver of multinationals, saying it could lead to more disputes between tax authorities. The standards aim to discourage companies from using "commissionaire structures" to avoid creating a permanent establishmentÔøΩwhich is subject to taxÔøΩin a jurisdiction. Instead of having such an entity, some companies hire agents to conclude contracts on their behalf, and avoid being taxed. Under the OECD's new standards, the use of such agentswould create a taxable presence.

A U.N. official said any approach to taxing the digital economy should prioritize the tax base of developing countries to ensure an equitable international tax system.

Italy's new 3 percent tax on digital advertising revenueÔøΩone of the first in Europe to take effect this yearÔøΩdoesn't address exactlywhowould be subject to the tax or how itwould be calculated. The lawwas passed quickly at the end of last year, leaving Italy's tax authority to hash out details in a decree that could be released thisweek.

A hallmark of U.S. tax reform is its provisions focused on deemed "intangible" income, including: a new foreign income inclusion rule for global intangible low-taxed income under new § 951A, and a new deduction for domestic corporationswith respect to their GILTI and foreign-derived intangible income under new § 250. In proposed regulations under § 250, issued on March 4, 2019, the Department of the Treasury and the IRS detail the intended interaction of these provisions to "neutralize the role that tax considerations playwhen a domestic corporation chooses the location of intangible income attributable to foreign market activity.

A deduction for exports, introduced in the 2017 tax overhaul, is "most likely breaching U.S. obligations under theworld Trade organization," the European Unionwrote in a letter to the U.S. Treasury Department and Internal Revenue Service.

The IRS provided partnershipswith some clarity onwithholding requirements for a new tax on gains from exchanges of partnership stakes involving foreign investors May 7. Publicly traded partnerships such as Blackstone Group LPÔøΩwhich recently announced its plan to switch to C corporation statusÔøΩhave eagerly anticipated the proposed rules (REG-105476-18), as keeping track of exchanges of partnership interest can be a daunting task for large entities like the private equity giant.

IRS proposed rules require companies to go to "inordinate lengths" to prove they qualify for a tax benefit for exporters, the Silicon Valley Tax Directors Groupwrote in a May 6 letter to the agency.

EU member states need to agree on a unified position as efforts to rewrite global corporate tax rules speed forward, Pierre Moscovici, a top European Commission tax official, told member state finance ministers.

Deputy Finance Minister Arturo Herrera confirmed the plans in an interview at Bloomberg News offices in Mexico City,while declining to elaborate. Bloomberg reported in November that the previous administration reached an agreementwith Uber Technologies Inc. inwhich the platformwillwithhold taxes from partnerswho gain income from both its ride-hailing and food delivery services.

Proposed regulations that require foreign partnerswho transfer interests to pay taxes via a newwithholding rule show that Treasurywas largely listening to taxpayer concerns, according to practitioners.

If the Australian Labor Party is elected, then itwill require companies to disclose to shareholders any business dealings in countries on a government tax haven blacklist,whichwill include the Cayman Islands.

The executive board of the International Monetary Fund noted the findings of a paper presented in March that stated that a tax based on a carbon emissions price is a better tool for mitigating climate change than cap-and-trade or other tax schemes because itwould lead to greater emissions reductionswhile raising far more revenue.

A tax based on a carbon emissions price is a better tool for mitigating climate change than cap-and-trade or other tax schemes because itwould lead to greater emissions reductionswhile raising far more revenue.

Robert Goulder takes a critical look at Sen. Elizabethwarren's proposal for a corporate surtax based on reported earnings drawn from financial statements.

Drafters of documentation provisions for the foreign-derived intangible income deduction for general services could learn something from other rules already on the books, lest taxpayers be saddledwith an "unduly burdensome requirement."

The Tax Executives Institute has commented on proposed regulations (REG-104464-18) on the deduction for foreign-derived intangible income and global intangible low-taxed income, addressing many issues, including the documentation requirements for "foreign use" and business services.

The Kenya Revenue Authority on May 3 issued a public notice confirming that domestic e-commerce operations are responsible for self-assessing, reporting, and paying taxes in Kenya.

Denmark's prime minister has announced general electionswill take place June 5, raising questions aboutwhether the incoming government could change the country's stance on the taxation of the digital economy.

The Canadian government is losing millions of dollars in tax revenue on digital goods from abroad and is failing to maximize sales tax revenue from e-commerce, according to a Canadian budgetwatchdog.