2020

TheG-20continues to push forward on anOECD-led solution to modernize the global tax system, since countries hit hard by COVID-19will soon need to think about economic recovery, a top Saudi minister said.

In this report, the authors trace the development of theIRS Large Business and International Division's new approach to transfer pricing enforcement, and they explain the practical implications for taxpayers and advisers.

The OECD inclusive framework is in the midst of something historic, assuming it can finish the job. The ensemble of 137 jurisdictions is trying to revise the international consensus,which for the past century has determined how corporate profits are divvied up among governmentswith rival tax claims. That's no small task. Thework is being done at the behest of the G-20 nations, and it's the type of globally coordinated mega-project that comes around only once in a generation.

In this article, the author examines the definition of a resident alien undersection 7701(b)in the context of the coronavirus pandemic.

Theworld needs to stand together, not only to fight the coronavirus pandemic, but also to agree on an OECD solution to update global tax rules for the digital age, Germany's finance minister said.

U.S. taxpayers looking to take advantage of net operating loss relief under the coronavirus stimulus bill may find themselves facing the difficult task of reconsidering previously taken return positions related to complicated transition tax calculations.

HM Treasuryhas proposed changing the rules to allow skilled nonresidents to come to the United Kingdom to helpwith its COVID-19 responsewithout affecting their tax residency status.

In this article, the author discusses the impact of the proposed abolishment of India's dividend distribution tax,with a particular focus on how the change may affect the overall investment climate.

In this article, the author considers the use of alternative forms of dispute resolution to resolve tax treaty disputes, focusing on the potential benefits of and obstacles to using mandatory binding arbitration to resolve transfer pricing disputes, including those that may arise under theOECD's unified approach for allocating profits in the digital economy.

New guidance on hybrid mismatches may include small measures of relief for taxpayers, but practitioners hoping for bigger changes from earlier guidance may be disappointed, if not surprised.

In this article, the authors consider the state of digital services taxation following theOECD's initiative to develop global digital tax rules.

While Switzerland has improved its exchange of information mechanisms, including adding more staff to handle data requests, it must do more to improve its beneficial ownership data availability, theOECD's transparency body said.

TheIrish Revenue Commissionersare calling the COVID-19 pandemic a case offorce majeure, saying that a taxpayerwill not suffer negative tax repercussions for being present in Ireland because of travel restrictions.

The Finnish tax administration cannot recharacterize an intragroup lender as a service provider because taxpayers' transactions must be respected as structured unless theywere undertaken for avoidance, according to Finland'shighest courtin tax disputes.

Robert Goulder examines how public country-by-country reporting almost made it into Congress's pandemic relief legislation.

TheOffice of the U.S. Trade Representative(USTR) said itwill continue towork toward the elimination of unilateral digital services taxes,which it says are key roadblocks to international digital trade.

The COVID-19 pandemic has raised tax residency concerns for individuals and businesseswith employeeswho have been forced to remain in foreign countries and could face unforeseen tax obligations because of government-mandated lockdowns.

In this article, the author considers the EU tax policy agenda outline laid out in the first tax policy speech ofPaolo Gentiloni, the new EU commissioner of the economy.

The U.K. digital services tax might be in effect, but it should be suspended to give companies grapplingwith the COVID-19 crisis some relief, a tech trade group representative said.

Multinational businesseswith prior years' deemed repatriation income maywant to take advantage of the special net operating loss carryback rules in the coronavirus stimulus package, a practitioner says.

Two more industry groups are dialing up the volume on calls to their respective governments to delay the timeline of theOECD'swork on a global corporate tax overhaul in light of the coronavirus pandemic.

Not all taxpayerswillwant to take advantage of the changes to the interest deduction limitation in the latest round of coronavirus legislation, according to a practitioner.

The U.K. tax authority began seeking public input on a proposed rule to require large businesses to notify itwhen taking an uncertain tax position they believewill be challenged.

HM Revenue & Customs issued a consultation to determinewhether new rules meant to prevent companies from manipulating differences in national tax systems may hit some legitimate lending relationships.

The U.K. government published guidance to help multinational companies navigate placeswhere the country's digital services tax interactswith other corporate tax measures, including transfer pricing rules and similar digital levies overseas.

Tax officials from around theworld face immense pressure to negotiate an overhaul of the international tax system at the OECD by the end of the year, even as the coronavirus pandemic brings mostwork around theworld to a halt.

Taxpayers are having to go to "extreme lengths" to claim the foreign derived intangible income (FDII) deduction under US tax rules. One tax director at a medical device company talks to ITR about the challenges.

A Swedish court has ruled against thermal camera producerFLIR Systemsin a dispute concerning an intangible transfer to a Belgian branch, holding that the tax agency correctly denied a group subsidiary's notional tax deduction.

Nonresident e-commerce operatorswill now have to pay a 2 percent tax on revenues from the sale of goods and services to Indian consumers, after the government broadened the scope of its equalization levy regime.

Practitioners are discovering that business-friendly changes to net operating losses and interest deduction limitations in legislation responding to the coronavirus economic crisis could also adversely affect multinationals because of interactionswith other international provisions.

Mindy Herzfeld examines U.S. Treasury options for alleviating the economic blowback of the coronavirus pandemic, questioningwhether further relief has been left on the table.

In this article, the authors discuss newly introduced research and development tax incentives in Germany, focusing on eligibility requirements, determination of tax relief, and international cooperation.

Payments to an Australian company for supplies of software services do not qualify as fees for technical services but should be further examined to determine if they qualify as royalties, theDelhi High Courtheld.

Prime MinisterMikhailMishustin said Russia maywithdraw from its tax treatieswith specific countries that refuse to impose a 15 percent tax on individuals transferring their dividend income abroad.

Treasuryshould postpone theOECD'swork on updating global corporate tax rules for the digital age as companies and governments continue grapplingwith the economic fallout of the coronavirus crisis, a major trade group said.