2020

Judge Albert G. Lauber of the U.S. Tax Court ruled that the U.S.-U.K. tax treaty protecting certain British enterprises from U.S. federal income taxes does not protect the U.K. company from the IRS increasing its taxable income by nearly $50 million.

In the last two years, dozens of governments have proposed or introduced unilateral tax measures to tax foreign-based technology companies. The new tax innovations include specialwithholding taxes, diverted profit taxes, minimum taxes, and digital services taxes. The rise of these unilateral measures threatens an international tax 'war' among governments that could stiflenew business models or even the spread of the global digital economy. This article reviews how international reform efforts have failed to constrain aggressive international tax planning and how the global digital tax conflict masks a growing dissatisfactionwith how to tax value associatedwith global transactions.The author concludes thatacoordinated solution that creates an economic presence test (a Quantitative Economic Presence Permanent Establishment) and modifies how tax revenues are divided between countries (e.g., the Residual Profit Split by Income proposal) is the bestway to address these global developments.

Officials to hold talks to head off new round of US trade sanctions

Internet company to consolidate all of its intellectual property in the US

Austria's coalition government has announced a four-year program that calls for a corporate tax cutfrom 25 percent to 21 percent, aswell as a revised goal of climate neutrality by 2040.

Although tax avoidance by multinationals has become an international political priority, it remainsunclearwhether anti-profit-shifting measures are economically beneficial for either high-tax or low-taxcountries, according to an IMFworking paper.

The OECD isworking at a breakneck pace to find a multilateral solution to update the internationalcorporate tax rules for the digital age, and going into 2020, the stakes for thatwork have never been higher.

The outlook for U.S. tax treaties and the OECD multilateral instrument in 2020 seems uncertain,particularly in light of the stormy international trade climate among major trading nations, practitioners say.

Automatic exchanges of jurisdiction-based reports that multinational companies file about their tax activitiesworldwide are an unintended outcome of pro-transparency efforts that may inundate tax administrationswith confusing data, the Organization for Economic Cooperation and Development has said.

An abrupt about-face by the U.S. on an international project to overhaul the global tax system has revealed deep divisions among American businesses over the proposal,which could hike their foreign taxes.

States' slow responses to the 2017 federal tax overhaul's provisions on taxing international income have created uncertainty that hampers growth, the Tax Foundation said Thursday in a report that also criticized certain states' partial adoption of the overhaul.

Austria's finance minister has told his German counterpart he can't support Germany's plan for a financial transaction tax, presenting a potentially serious roadblock to efforts by 10 European Union countries to reach agreement on the tax.

U.S. multinationals have repatriated over $1 trillion since Congress overhauled the revenue code in late 2017 to let companies bring home their offshore earnings tax-free after a one-time payment, according to data released Thursday by the U.S. Commerce Department.

The U.S. Treasury Department is consideringwhether to retroactively apply a new high-tax exception to global income, a government official said Thursday.

Sunday marks two years since the GOP's Tax Cuts and Jobs Act sped through Congresswithout a single Democratic vote, and lawmakers are still arguing over the law's impact on federal budget deficits, economic growth and business investments.

The European Parliament advanced a resolution on December 18 to adopt an EU standard to tax digital companies in case the OECD fails to find consensus on its global approach.

Although 2019 delivered two highly anticipated Ninth Circuit decisions in transfer pricing cases,disputes concerning intangible valuation and differing interpretations of the arm's-length standard appearpoised to continue unabated in 2020

EU finance ministers are expected to discuss international reform of digital taxation during anEconomic and Financial Affairs Council meeting in January 2020

Mindy Herzfeld analyzes the various factors that threaten the future of today's international taxregime