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Int'l Tax News

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Trump Flirts With the Ultimate Tax Cut: No Income Taxes at All

  • By Andrew Duehren

The former president has repeatedly praised a period in American history when there was no income tax, and the country relied on tariffs to fund the government.

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French Lawmakers to Consider Digital Tax Increase Proposals

  • By Stephanie Soong

The French National Assembly will soon discuss proposed amendments to the 2025 draft finance bill, which would increase France’s controversial digital services tax by at least 2 percentage points to raise much-needed revenue.

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Global Implementation of Pillar 2 Is Top Priority, Hoekstra Says

  • By Elodie Lamer and Stephanie Soong

Wopke Hoekstra, EU commissioner-designate for taxation, told members of the European Parliament that while nearly all multinational enterprises will pay the global minimum tax under pillar 2 by 2025, the system is still at risk.

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European Parliament Members Have Carbon Tax Demands for COP29

  • By Amanda Athanasiou

An environmental committee of the European Parliament has adopted a set of demands for the upcoming U.N. Climate Change Conference that call on the European Commission to push for carbon pricing outside the bloc.

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Tariffs: Back to the Future

  • By Doron Narotzki

Doron Narotzki explores the resurgence of high tariffs in U.S. trade policy, beginning with the Trump administration and continuing into the Biden administration, that were initially intended to protect domestic industries and reduce trade deficits, but have instead led to increased consumer prices, strained diplomatic relationships, and harmed global trade dynamics.

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Untangling Corporate AMT Regs, Loper Bright's Ongoing Effect, and Stock Buyback Regs

  • By Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler

Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler review the extensive proposed corporate AMT regs, explain the ongoing effect of Loper Bright, review comments on stock buyback regs, and offer updates on the Treasury Inspector General for Tax Administration’s economic substance doctrine report, taxpayers’ compliance assurance process eligibility, and IRS advice on foreign-derived intangible income and 245A dividends received deductions.

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What Authority for Proposed Dual Consolidated Loss Rules?

  • By Lee A. Sheppard

Lee A. Sheppard examines the recently released dual consolidated loss proposed regulations.

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Proposed CAMT Regs Raise Questions About Viability of Minimum Tax Regimes

  • By Mindy Herzfeld

Mindy Herzfeld examines the increasing complexities that multinational corporate taxpayers face in light of the recently released proposed corporate alternative minimum tax regulations, including the significant differences between accounting and income tax treatment of income.

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Pillar 1 Is a ‘Rough Proxy,’ EU Competition Commissioner Says

  • By Elodie Lamer

Margrethe Vestager, executive vice president of the European Commission and commissioner for competition, told members of the European Parliament that the global community should keep working on pillar 1 and on an alternative.

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Where Is China Now on Pillar 2?

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah explains the relationships between Chinese tax policy, pillar 2, and global multinational enterprises.

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U.S. Business Group’s Belgian UTPR Challenge Gains Traction

  • By Stephanie Soong

American groups and lawmakers are rallying behind a legal challenge filed in Belgium’s Constitutional Court against the undertaxed profits rule, but it could be a while before a decision is rendered — and success isn’t guaranteed.

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FDI vs. Double Taxation: Promoting Taiwan’s Investment in the U.S.

  • By Paul Poliakov

Paul Poliakov explains how resolving double taxation and other inefficiencies of the U.S. domestic law regime for taxing foreign corporations could improve Taiwan-U.S. business relations.

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Don't ‘B’ Left Behind: How Companies Need to Prepare for Amount B

  • By Kartikeya Singh, Anthony Tufo, Shubhana Sattar, and Marco Fiaccadori

Kartikeya Singh, Anthony Tufo, Shubhana Sattar, and Marco Fiaccadori explain the OECD inclusive framework’s amount B and the large effect it is likely to have on transfer pricing. They analyze the ways in which multinational enterprises can prepare for the various iterations that could arise as jurisdictions choose how to react to amount B.

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Competent Authority Resolutions and the Creation of BEAT Liability

  • By David Farhat, Mayowa Olujohungbe, and Bryan McGrane

David Farhat, Mayowa Olujohungbe, and Bryan McGrane explain why tax authorities can and should expediently address base erosion and antiabuse tax liability that may arise from taxpayers’ use of the advance pricing and mutual agreement program.

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Ireland Proposes Amount B and Global Minimum Tax Amendments

  • By Stephanie Soong

The Irish Department of Finance has issued draft legislation calling for amendments to existing laws to implement the OECD amount B political commitment and incorporate further global anti-base-erosion administrative guidance.

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Final IP Repatriation Regs Closely Follow Proposed Rules

  • By Andrew Velarde

Final rules on the termination of income inclusions for repatriated intangible property track closely to proposed regs, with the drafters declining significant expansion over administrability and scope concerns and refusing to make the rules retroactive.

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Australian CbC Reporting: The True Cost of Unprincipled Transparency

  • By Anne Gordon

Anne Gordon explains why overzealous reporting legislation will negatively affect Australia’s international business relationships.

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Treatment of U.S. Multinational IP Transfers in a Pillar 2 World

  • By Jason Yen and Bona Chung

Jason Yen and Bona Chung provide examples that highlight the complexities of analyzing IP transactions under pillar 2 and explore questions that require further guidance.

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India Mulling Ways to Adopt 15% Global Minimum Tax

  • By Shefali Anand

India continues to deliberate on adopting the OECD’s 15% global minimum tax—also known as Pillar Two, a senior tax official said Thursday.

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Cruise Lines Seek Carve-Out for OECD's Global Minimum Tax

  • By Lauren Vella

The OECD should allow a carve-out in the global minimum tax rules for mobile, tangible assets like ships and airplanes, according to an industry group representing cruise lines.

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Portugal seeks to become low-tax haven for young people

  • By Barney Jopson and Sérgio Aníbal

Portugal is planning to turn itself into a low-tax haven for young adults by offering a decade of tax breaks to people starting their careers in an effort to halt a growing brain drain.

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Donald Trump pledges to end double taxation for expat Americans

  • By Ilya Gridneff

Donald Trump has said he will end “double taxation” for millions of Americans living overseas if he wins the US presidential election next month.

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Loper Bright Blocks Payment Loss Rules, Business Groups Assert

  • By Andrew Velarde

Business groups and associations have responded forcefully in comments criticizing Treasury’s disregarded payment loss regs, arguing that the government lacks authority to issue the rules, as the Supreme Court made clear in Loper Bright.

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Swiss Government Opposes New Taxes on Financial Transactions

  • By Jan Stojaspal

The Swiss government expressed resistance to using financial transaction taxes to finance the country’s old age pension system.

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Surprise CAMT Rules on Foreign-Parented Groups Are About Parity

  • By Andrew Velarde

Proposed corporate alternative minimum tax regs’ provisions pertaining to foreign-parented multinational groups, which have caught some tax experts by surprise, were drafted to ensure parity between foreign and domestic entities, according to Treasury.

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Will the CJEU Go Easy on Ikea?

  • By Robert Goulder

Robert Goulder comments on the European Commission’s reinvigorated state aid case against the Netherlands and Ikea.

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EU’s Highest Court Tells U.S. Taxpayers to Pay for a New Marshall Plan

  • By Mindy Herzfeld

Mindy Herzfeld examines the saga of European state aid cases and the costs of the Court of Justice’s recent decision in European Commission v. Ireland for the U.S. government — and its taxpayers.

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Legal Service Advises Withdrawal of EU Transfer Pricing Proposal

  • By Elodie Lamer

The EU Council legal service recently warned member states that the draft transfer pricing directive is getting in the way of an agreement on a nonbinding joint transfer pricing forum.

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Brazil Introduces Domestic Minimum Tax in Line With Pillar 2

  • By Stephanie Soong

Brazilian President Luiz Inácio Lula da Silva has issued a provisional measure providing for a domestic minimum tax intended to be qualified as in line with the OECD’s global anti-base-erosion rules.

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The U.N. Model Tax Treaty’s Shift Away From Physical Presence: An Analysis of Draft Article XX

  • By Hafiz Choudhury

Hafiz Choudhury outlines the progress of draft Article XX on fees for services within the U.N. model tax convention’s evolution away from reliance on physical presence.

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UN Global Tax Talks Duplicating Work at OECD, EU Says

  • By Saim Saeed

The European Union said negotiations for a new corporate tax treaty at the United Nations were potentially duplicating those taking place at the Organization for Economic Development and Cooperation in Paris.

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Week in Insights: OECD Needs to Find Pillar Two's Happy Medium

  • By Andrew Leahey

As the OECD continues to promote Pillar Two, balancing the goal of fostering tax fairness with the need to avoid excessive compliance burdens is a challenge.

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Rachel Reeves to spare PE bosses top UK tax rate in compromise on ‘loophole’

  • By George Parker and Michael O’Dwyer

Rachel Reeves, the UK chancellor, is not expected to hit private equity bosses with the top 45p tax rate in this month’s Budget, as she looks for a compromise deal to close tax “loopholes” that does not drive investors out of Britain.

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European Commission Delivers First Blow to Hungary’s Retail Tax

  • By Elodie Lamer

The European Commission is acting on a complaint by foreign-controlled companies operating in Hungary that the country's discriminatory retail tax regime puts them in a much higher tax bracket than domestic retail franchises operating there.

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Four EU Member States Referred to High Court for Pillar 2 Delay

  • By Stephanie Soong

The European Commission has referred Cyprus, Poland, Portugal, and Spain to the EU’s highest court after warning them twice about their slow adoption of the EU’s directive for implementing global minimum tax rules.

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EU member states agree to impose tariffs on Chinese electric vehicles

  • By Andy Bounds, Edward White, and Kana Inagaki

EU member states have agreed to impose tariffs of up to 45 per cent on imports of Chinese electric vehicles, ratcheting up the biggest trade dispute between the economic superpowers in a decade.

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Study Suggests a Levy on Companies to Finance EU Agencies

  • By Elodie Lamer

Ten years of case law involving the EU banking union show that the EU has legal grounds to levy a contribution on companies in exchange for services, according to a European Parliament study.

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Shareholders, Creditors, and GLOBE: A New Perspective

  • By Fabian Kratzlmeier

Fabian Kratzlmeier argues that pillar 2’s group approach disregards the interests of creditors and minority shareholders, and he explores how long-standing concepts of civil, corporate, and bankruptcy law could be used to protect those interests within the global anti-base-erosion framework.

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Apple May Change the Equation for EU Transfer Pricing Directive

  • By Ryan Finley

Ryan Finley explains why the EU member states may want to reconsider their objections to a transfer pricing directive after European Commission v. Ireland.

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European Central Bank President Suggests 28th Corporate Rulebook

  • By Elodie Lamer

Christine Lagarde, president of the European Central Bank, said an EU capital markets union could be achieved through a 28th regulatory regime, including on taxation.

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U.S. Group Backs UTPR Legal Challenge in Belgian Court

  • By Stephanie Soong

The U.S. Chamber of Commerce has expressed strong support for another American business group’s legal challenge against the undertaxed profits rule in the Belgian Constitutional Court, saying the measure is “fundamentally flawed.”

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UF Tax Incubator: Gutting Subpart F?

  • By Jeffery M. Kadet

Jeffery M. Kadet responds to a recent article on reforms to the subpart F and global intangible low-taxed income regimes, commending the authors’ efforts but arguing that their proposals should be carefully considered, given whom they would benefit.

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OECD Report Provides Guidance on Crypto-Asset Reporting

  • By OECD Publishing

The OECD has published guidance for tax administrations on exchanging information on crypto assets. The document, dated Oct. 2, features a user guide for the XML schema used in the automatic exchange of information under the Crypto-Asset Reporting Framework, or CARF.

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EU Calls for Fair Balance of Interests in U.N. Tax Process

  • By Elodie Lamer

EU member states’ ambassadors are ready to adopt an official position on the future of the U.N. tax negotiations that urges more analysis and consensus-based decision-making.

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As the Apple Falls: The EU’s Reinvigorated Case Against Nike

  • By Robert Goulder

Robert Goulder examines the European Commission’s state aid case against Nike in light of the recent Apple judgment.

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The U.S. Tax System’s Curious Embrace of Manufacturing Job Losses

  • By J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay

J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay explain how the subpart F regime and the global intangible low-taxed income regime together contribute to a long-running decline in domestic manufacturing employment, and they argue that the best approach to fixing the problem is worldwide taxation without deferral, not pillar 2.

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Confines of Covered Inbound Transactions Under Notice 2024-16

  • By Laura E. Williams, Jennifer Franceschini, and Raza Janjua

Notice 2024-16 announces the government’s intent to issue regs to provide an adjustment to a domestic acquiring corporation’s basis of acquired CFC stock for covered inbound transactions. Laura E. Williams, Jennifer Franceschini, and Raza Janjua of PwC explain how the narrow definition of covered inbound transactions and the limitations outlined in Notice 2024-16 may leave taxpayers exposed to double taxation in many situations, and argue that future regulations should provide for expanded relief.

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Ireland Extends Tax Benefits for Investors in Budget

  • By James Munson

Ireland revealed plans Tuesday to extend a range of tax benefits to attract risk finance into the country as part of a pre-election budget. The Department of Finance is proposing to extend the Relief for Investment in Corporate Trades benefits by two years, a budget document outlining tax measures said, putting them into effect until Dec. 31, 2025.

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Justice Was Done in Apple

  • By David G. Chamberlain

David G. Chamberlain responds to Lee A. Sheppard’s analysis of the EU Court of Justice’s ruling in the Apple state aid case and argues that the Court’s ruling was correct.

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Argentina's New Tax Incentives to Shore Up Foreign Investments

  • By Augusto Mancinelli and Marcelo Etchebarne

Argentina’s economic reform law has significant tax implications for various industries. The law, issued by decree on Aug. 22, includes a large investments incentive system known as RIGI. A key feature of the measure is a stability provision for a 30-year period, encompassing tax, customs, legal, and regulatory incentives.

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