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2019

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Fixing our 'America Last' tax policy


Tax Cuts and Jobs Act is a regressive response to the challenges posed by today's global economy. Not only do the vast majority of the tax benefits from the legislation accrue to those at the top of the income distribution, but the legislationweakens the health security of ordinary Americans. Reduced spending on health insurance subsidies for poor Americanswill increase the number of uninsured Americans and generate more expensive premiums for those that remain insured.

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EU Commission Hopeful Backs Continental Minimum Corp. Tax


A top candidate for the European Commission presidency said Thursday he supports a Europewide minimum corporate tax because European Union countries are no longer powerful enough to extract a fair amount of revenue from the largest companies on their own.

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Elizabeth Warren Proposes New Corporate Tax


Democratic presidential candidate Elizabethwarren is proposing a new 7% tax on the largest, most profitable U.S. companies, a move thatwould increase corporate tax collections by about 30% over the next decade.

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Germany's Scholz Wants Progress on Global Corporate Taxation

  • By Reuters

German Finance Minister Olaf Scholz told Reuters in an interview onwednesday hewould urge financial leaders during meetings inwashington later thisweek to aim for a minimum level of corporate taxation globally.

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Why more tax reform is inevitable


The 2017 tax law looks appealing to many citizens because it handed out a lot of money thatwould otherwise have gone to the Treasury. However, the oversized budget deficits, caused in part by the unavoidable aging of our population,will force lawmakers to revisit that tax law. The American people should be prepared for another very different dose of tax reform.

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Investors want a global standard for MNE tax disclosures


Investors are using multinational companies' tax disclosures, such as country-by-country reports, to inform their investment decisions - andwant consistent disclosure formats to make comparisons easier.

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Taxing the Digital Economy Post BEPS ... Seriously


For years the advent of the digital economy has left countries stumped in their attempt to tax income earned by foreign firmswithout physical presencewithin their jurisdiction. International organizations and their member countries have failed in their attempts to tweak the rules of the international tax regime and address these challenges presented by the digital economy. This article argues that such conservative approach could notwork, and fundamental reform is inevitable.

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Austria Announces Five Percent Digital Tax


The Austrian Government announced on April 3, 2019, a package of tax measures aimed at the digital economy, including a five percent tax on revenue derived from the sale of digital advertising services and the removal of the low-value VAT exemption threshold.

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Australia Issues Ruling On Hybrid Mismatch Rules


The Australian Taxation Office has opened a consultation on a draft Law Companion Ruling on the targeted integrity rule thatwill apply under the new hybrid mismatch regime.

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EU Justice Commissioner Addresses Digital Taxation at Brookings Institute

  • By Tax Analysts

Vera Jourová, European Commissioner for Justice, Consumers, and Gender Equality, spoke about digitalization, data protection legislation, and challenges that the United States and European Union face regarding online data control in an April 11 speech at the Brookings Institute.

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Trade Misinvoicing Creates Trillion-Dollar Value Gap, GFI Says


Deliberate misstatements on trade invoices have created a trillion-dollar gap in the actual value of goods, leading to about $200 billion in annual tax revenue losses, according to estimates by Global Financial Integrity (GFI).

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Latin American Tax Challenges Sway Favored Digital Solution


Latin American countries' preferred proposal for addressing the tax challenges of the digital economy is driven by an eroding tax base, according to a tax specialistwith the Inter-American Development Bank (IADB).

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EU Money Laundering Blacklist to Get a Reboot, Commissioner Says


A revamped money laundering blacklistwill be submitted to the EU Council in October, EU Justice Commissioner Věra Jourová told Tax Notes.

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OECD Digital Work Expected to Yield Small Shift in Taxing Rights


A modest reallocation of taxing rights that is palatable to countries losing some tax revenues could be key to addressing the challenge of generating OECD consensus on new global tax rules.

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Tax Transparency in Fits and Starts


Mindy Herzfeld describes recent proposals to make corporate tax data more transparent, including those by the Financial Accounting Standards Board and the Global Reporting Initiative.

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Consolidated Groups Still Facing Hybrid and DCL Problems


In news analysis, Carrie Brandon Elliot reviews how the new hybrid proposed regulations solve some, but not all, of thewell-known problems related to dual consolidated losses.

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The Limits of Friendlier Tax Administration, Part 2


In news analysis, Lee A. Sheppard discusses emerging trends in tax collection in developing economies and how these are causing difficulties for traditional organizations like the OECD and IMF.

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Canada Seeks International Consensus on Digital Taxation


Canadian Finance Minister Bill Morneau reiterated that Canada is awaiting the OECD's report concerning digital taxation and noted the importance of the United States' position to Canada's future decisions.

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Mexican Government to Propose a Digital Services Tax in 2020


A recent statement by Deputy Finance Minister Arturo Herrera that the Mexican government intends to tax digital services has prompted concerns that pending legislation might be used to implement the plan.

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U.N. Transfer Pricing Manual Draft Updates Seek OECD Alignment


The U.N. has released a package of draft updates to its transfer pricing manual for developing countries, including a new chapter on financial transactions and revised profit-split guidance consistentwith recent OECD updates.

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Tax Committee Leaders Caution Against Digital Services Taxes

  • By Tax Analysts

In an April 10 release, the chairs and ranking minority members of the Houseways and Means and Senate Finance committees expressed support for OECD negotiations on the digital economy and said digital service taxes, even on an interim basis, can have negative effects on U.S. businesses, the economy, and diplomacy.

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H.R. 2210 Would Repeal FIRPTA Provisions

  • By Tax Analysts

H.R. 2210, the Invest in America Act, introduced by Houseways and Means Committee member John B. Larson, D-Conn.,would repeal provisions of the Foreign Investment in Real Property Tax Act of 1980 concerning capital gains taxation of U.S. investments by foreigners, in addition to repealing other provisions to stimulate foreign investment in the United States.

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EU Energy Union Seconds Switch to Qualified Majority Voting


The EU Energy Union said it supports the European Commission's proposal to move away from unanimity to qualified majority voting (QMV) on energy taxation.

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Top Taxwriters Urge Collaboration on Digital Tax Problem


Countries shouldn't enact unilateral digital services taxes but should insteadworkwith the international community to find a solution, U.S. lawmakers urged in a statement.

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Minnesota Provision Creates GILTI Trigger for Combined Reporting


Minnesota House lawmakers have introduced a bill thatwould include foreign corporations that generate global intangible low-taxed income in the corporate unitary group.

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U.S. Treasury Criticism of EU Anti-Money Laundering Blacklist Shows Cracks in Financial Enforcement


In this article, the author discusses the process and rationale behind the EU's anti-money laundering blacklist and the U.S. Treasury's response.

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BEPS Aftermath: Mechanisms to Curtail Treaty Shopping and Abuse


In this article, the author examines OECD and U.S. approaches to counteract treaty shopping and abuse and provides a framework of topics that taxpayers might need to focus on to claim treaty benefits. He also explores the symbiotic relationship between U.S. tax treaty policy and the action plans released as part of the OECD's base erosion and profit-shifting project.

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Germany to mull carbon tax as part of national climate pact

  • By Associated Press

Germany's environment minister says the governmentwill discuss introducing a carbon tax as part of its national plan to curb climate change.

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Corporations are cheating the global tax system. World leaders can't afford to ignore it


There is no gap in the architecture of globalization more serious than the failure of nations to prevent global companies andwealthy individuals from escaping taxation through tax havens, accounting devices and pressure to bring down business tax rates.

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Czech Republic Implements ATAD Measures


The Czech Republic has published corporate income tax amendments in connectionwith its implementation of the EU's anti-tax-avoidance directive (ATAD). Most of the new measures took effect April 1.

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European Commission Speaks Out Against Tax Unanimity


The European Commission rerouted an informal discussion on growth and taxation by the Economic and Financial Affairs Council April 6 to promote a shift toward qualified majority voting in tax matters. Three member states said they oppose the move.

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France Must Cut Taxes Quickly to Quell Public Anger, PM Says


The French public is exasperated over the country's high tax burden, so the government must respond quickly and decisively, France's prime minister said following the close of a national consultation initiated after violent protests.

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Swiss Corporate Tax Reform- Considerations for Multinationals


The objective of the proposed Swiss corporate tax reform is to ensure that the Swiss corporate tax system is in linewith international minimal standards,which recognize as harmful the cantonal preferential tax regimes for holding, domicile and mixed companies. Accordingly, these privileged tax regimes need to be abolished by the cantons. The proposed new tax provisions are intended to achieve international acceptancewhile at the same time maintaining Switzerland's attraction for multinational enterprises.

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Treasury Pressed to Fix Tax Mistake That May Push R&D Offshore


The Treasury Department is being pressed by Republican lawmakers and business groups to correct a defect in a new tax on foreign earnings that has companies like biotech giant Amgen Inc. saying they may move their research and development operations offshore. They are asking Treasury to clarify how to properly allocate research and development expenses under the new rules,which are meant to ensure multinationals pay at least a minimum amount of tax on overseas profits earned in countrieswith lower tax rates than the U.S.

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Tax Treatment of Stock Payments High on Treasury's Agenda


The treatment of stock payments under the new base erosion and anti-abuse tax is high on Treasury's list of outstanding items to tackle, an official said. The Treasury Department has received comments on pending issueswith the BEAT, includingwhether non-cash or property payments, including stock payments or the assumption of a liability, should be captured under the new tax.

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Slicing the Shadow: OECD Consultation Highlights Profit Allocation Difficulties


Jeff VanderWolk of Squire Patton Boggs querieswhether the OECD needs to revise profit allocation rules to address digitalization.

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Germany, Netherlands Team Up to Push for Minimum Corporate Tax


Germany, Netherlands plan towork together to establish "minimum tax standard" to counter tax havens, according to joint statement supplied by Germany's Finance Ministry.

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Brace Yourself, Corporate America: Taxes Are About to Go Up


President Donald Trump's signature tax cuts are set to end starting 2021, and Corporate America must prepare for an increase in levies as it's unlikely Congresswill extend the stimulus, according to Morgan Stanley.

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France Must Stop Creating Taxes, Budget Minister Says


French Budget Minister Gerald Darmanin said March 29 that the state must stop creating new taxes and rather cut spending, in an interviewwith RMC radio.

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Digital Services- Tax Implications (Part 4)


The final part of this four-part Insight continues a review of the different forms of digital services tax introduced as interim measures in a number of jurisdictions until a global solution is reached.

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Rettig Doubles Down on Transfer Pricing Cases


IRS Commissioner Charles Rettig reiterated his intent to crack down on the use of complex offshore tax evasion techniques involving intellectual property.

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Euro-Wide Digital Tax Solution Could Spur Global Consensus


A European-wide digital tax could have driven a global solution to the challenges of taxing the modern economy, said EU Competition Commissioner Margrethe Vestager.

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Netherlands Ratifies OECD's Super Tax Treaty


The Netherlands officially ratified the OECD's multilateral "super tax treaty" designed to implement measures to prevent base erosion and profit-shifting in double-tax treaties March 29, joining 23 other jurisdictions.

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U.S. Digital Tax Plan Complex for Developing Countries: Official


The U.S. proposal to tax the digital economy could prove to be difficult to implement, especially for developing countries, an OECD official said. The complexity may put developing countries off from backing the U.S. proposal, according to Sophie Chatel, head of the Tax Treaty Unit at the OECD Center for Tax Policy and Administration.

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European Ministers Urge Action on Corporate Tax Reform


European Union finance ministerswill make a push to include corporate tax reform at the top of the European Commission's agenda at a meeting in Bucharest.

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Companies Must Prove Foreign Use or Face Losing Export Deduction


U.S. exporterswill lose their ability to take a deduction on foreign-derived income if they're unable to prove to the IRS that the exportswere intended for foreign use. Companies should have "reason to know" that their goods and serviceswere meant for foreign persons and foreign use, and provide documentation to substantiate that claim if the goods find theirway back to U.S. soil.

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OECD Digital Tax Solution Must Weigh Simplicity and Precision


Any solution to the digital taxation problemwill have to balance the desire for a simple solution against the need for precision, the OECDwarned. The Organization for Economic Cooperation and Development is grapplingwith the concepts as part of itswork to find solutions to taxing the digital economy, according to its senior officials.

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EU Aims to Unify Members on Digital Tax, Fall in Line With OECD


The European Commissionwill try to unite countries on digital tax proposals being discussed at the OECD to ensure the plan alignswith the bloc's plans to reform corporate tax.

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Snap AV: tax cuts = share buy backs


A new chart from Deutsche Bank's economicswizard Torsten Slok shows the effect of Trump's corporate tax cuts.

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Russia- Challenges of the Google Tax


There have been significant changes to theway electronic services are taxed in Russia. Anton Nikiforov of Pepeliaev Group discusses the challenges that foreign companies face and how these challenges can be overcome.

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