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Int'l Tax News

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Noose tightens on tax havens in global crackdown


Overlookingwhite sands and turquoisewater, One Cable Beach is the latest oceanfront condominium to be built on the sun-drenched coastline of the Bahamas. Yet its top selling point is not the natural beauty of its surroundings. Instead it is the financial privacy it offers investors trying to escape from a looming crackdown on tax evasion.
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EU Fails to Reach Deal on Foreign Country Hybrid Mismatches


European Union finance ministers have failed to agree on extending anti-tax avoidance rules to hybrid mismatchesÔøΩthe mismatch in tax outcomes due to different jurisdictional tax treatmentsÔøΩbetween member countries and foreign territories, amid disputes over financial sector exemptions and an implementation date.
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News Analysis: Reality Check on a Destination-Based Cash Flow Tax in 2017


Many in the tax and businessworld are excited about the possibility that 2017 could bring meaningful tax reform based on the reform blueprint released by the U.S. Houseways and Means Committee in June. But the destination-based cash flow tax proposed by the Republican planwould be a major overhaul of the code -- far beyond even the Tax Reform Act of 1986. It is far from certain that such a radical changewill be achievable.
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Apple, EU Clash in Public Ahead of Court Fight Over Tax Bill


Apple Inc. and European Union competitionwatchdogs clashed on a public stage for the first time since regulators ordered Ireland to claw back a record-breaking 13 billion euros ($13.9 billion) in back taxes from the company.
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Significant financing costs from Mexico's VAT bill 2017

  • By ITR Correspondent

A bill of tax amendments submitted by the Executive Branch and approved by the Mexican Congress included changes to Article 5-I of the Value Added Tax Law (VAT Law), regarding the creditable VAT of fixed assets or expenses incurred in preoperative periods (i.e. before generating VAT income on its activities).
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Planning for the Use of the United States as a Financial Haven: Part One


The United States has not agreed to participate in the Common Reporting Standard (CRS), relying instead on the Foreign Account Tax Compliance Act (FATCA) regime enacted in 2010 and initiated in 2014. United States participation in CRS is highly unlikely. Evenwith a change in control of Congress, CRS may be viewed as unnecessary because FATCA has been implemented by a series of intergovernmental agreements ("IGAs"), most ofwhich provide for reciprocal exchanges of information.
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Vestager Talks Apple, Tax, and Competition With France's Legislators


National legislators and tax authorities should consider taking a "second look" at Apple's old tax agreements, EU Competition Commissioner Margrethe Vestager told French legislators December 1.
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New Tax Rules on Corporate Inversions Face Uncertain Future


The U.S. Treasury Department spent nearly three years reshaping international corporate transactions, reinforcing the U.S. tax base and deterring inversions, the controversial maneuvers that put companies' addresses in low-tax countries.
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Trump tax plan may collide with EU tax crackdown


President-elect Donald Trump's plan for a corporate tax overhaul next year could bolster the European Union's efforts to reduce international avoidance through tax reform efforts of their own ÔøΩ but don't count on it.
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EU Mulls Substance Test to Determine Zero-Rate Tax Havens


European Union member countries are considering a "substance test" to determinewhether a country or jurisdictionwith a zero corporate tax rate qualifies as a tax haven that doesn't reflect "real economic activity."
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Taxing Untaxed Foreign Income May Help U.S. Companies in the Long Run, Stack Says


Some U.S. multinationals may owe more tax under the global minimum tax proposed by the outgoing Obama administration, but it could prevent decades of volatility in the international tax environment and unilateral anti-profit-shifting measures, according to Robert Stack, Treasury deputy assistant secretary for international tax affairs.
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OECD Anticipates Global Market Reaction to Trump's Tax Plans


The OECD has highlighted awidespread expectation of significant directional change in macroeconomic policy following the U.S. elections in November. It said in its latest global economic outlook that the likely evolution of fiscal policy over the next two years could affect growth prospects and inflation in economies beyond the U.S.
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EU Seeks VAT Changes to Boost E-Commerce, Digital Publications


The European Commission is set to propose an overhaul of electronic commerce ruleswhile expanding the one-stop-shop value-added taxation system for collecting and distributing the levy.

In addition, the commissionwill aim to permit European Union member states to reduce VAT rates on electronic publications, including newspapers, magazines and e-books.
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After Google, Indonesia targets Facebook over unpaid taxes and fines


After Google, Indonesia is targeting social network giant Facebook for unpaid taxes and penalties.

The government's latest move comes after Googlewas expected to reach a tax settlementwith Indonesia in the next fewweeks. As per the proposed settlement, Googlewould pay back taxes and fines, and agree to a new calculation of profits made in the country.
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European Parliament Backs VAT Reverse Charging


The European Parliament gave overwhelming support to the use of value-added tax reverse charging by European Union member states in order to clamp down on fraud for cross-border sales that annually costs governments close to $200 billion.
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House GOP Business-Tax Plan Upends U.S. Policy, Bares Corporate Fault Lines


Fault lines inside the corporateworld are emerging over a proposed rewrite of the U.S. tax code, pitting importers against exporters. At the heart of the fight is a Republican plan in Congress thatwould impose corporate taxes on importswhile eliminating them from exports, a move thatwould upend decades of tax policy.
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EU Approves Automatic Exchange of Bank Data


The European Parliament has overwhelmingly approved legislation thatwould allow tax authorities across the EU to automatically share bank informationwith other member states and to implement registers recording the beneficial ownership of companies and trusts.
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UK Prime Minister reignites 'race to the bottom' on corporate taxes


UK Prime Minister Theresa May has once again sparked the so-called 'race to the bottom' on corporate tax rates after she said shewants the UK to have he lowest corporate tax rate among G20 member countries.
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Global Competition to Cut Corporate Taxes Heats Up


An international race to lower corporate taxes is back in the global spotlight after Britain recommitted to slashing rates and as the election of Donald Trump puts U.S. corporate-tax overhauls on the front burner.

U.K. Prime Minister Theresa May on Monday officially endorsed a move by Britain's previous Conservative government to lower the main corporate rate there to 17% by 2020, from today's 20%. President-elect Donald Trump promoted on the campaign trail a 15% U.S. headline corporate tax-rateÔøΩdown from the current 35%.
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China's Tax Reform May Hit the Country's Wealthiest


Days after taking the job, Chinese Finance Minister Xiao Jie is accelerating income tax reforms that could help fill government coffers by digging into the pockets of thewealthiest.

A new office established at the ministry this monthwill be specifically devoted to handling payments from individuals, separating that responsibility from corporate tax collection. Tax authorities also are getting more power to monitor overseas accounts of citizens and track the finances of thewealthiest,whose incomes aren't always on the government's radar.
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U.S. Tax Review (10)



Tax Analysts

In this article, the author discusses recent U.S international tax developments, including section 385 regulations and foreign tax credits, various IRS rulingswith international implications, the DreamWorks Animation case, and recently released OECD documents related to the mutual agreement procedure.
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News Analysis: Populism and State Aid


Business and political eliteswhowere surprised by the populistwave manifested in the U.K.'s Brexit vote last June received an even ruder awakeningwith the results of the U.S. presidential election.

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Belgium Likely to Scrap Fairness Tax


A Belgian tax on dividend distributions affecting large companieswill likely be abolished if the European Court of Justice follows a recent opinion by its highest adviser that it fails to complywith European law.

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Business wary over further cuts to UK corporation tax


Theresa May on Monday promised business leaders to maintain the "lowest corporate tax rate in the G20", paving theway for further reductions if Donald Trump fulfils a promise to cut the US rate to 15 per cent.
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UK's Autumn Statement: A fiscal reset or just a tune-up?


UK Chancellor of the Exchequer Philip Hammond is about to deliver his first budget statement at a timewhen tax uncertainty looms on every business as a result of the Brexit vote, butwhat could his budget look like?
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Hungary to offer EUs lowest corporate tax rate


Hungary's government is to cut its corporate tax rate to the lowest level in the EU in a sign of increasingly competitive tax practices among countries seeking to lure foreign direct investment.

Prime Minister Viktor Orban said a new 9 per cent corporate tax ratewould be introduced in 2017, significantly lower than Ireland's 12.5 per cent.

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Trump's Election Could Change International Taxes Overnight


An election that turned the globe upside down may leave the international taxworld changed overnight aswell.

After Donald Trump's surprisingwin in the 2016 presidential election, the chances of a systemwide tax overhaulÔøΩonce seen as years awayÔøΩis now possible in a matter of months.

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Treasury Vows to Finalize Expiring International Guidance


The U.S. Treasury Department'swork on several high-priority guidance projectswill continue, including the finalization of two temporary regulation international tax packages set to expire before the new administration is sworn in, Treasury officials said November 16.

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News Analysis: Range of Foreign Responses Predicted to Trump Tax Plans


While many of the finest tax minds in the U.S. areworking overtime trying to divine the direction that the incoming Trump administrationwill take the country's tax policy, their counterparts overseas are scratching their heads about how foreign governmentswill react if those inchoate policies prove harmful to their national interests.
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France Investigating 500 Taxpayers After Panama Papers Leaks

  • By AP

The French government is investigating the tax records of about 560 taxpayers based on leaked documents from a Panamian law firm.

The budget office of the Finance Ministry said Thursday its experts have studied the leaked information and are now digging deeper into 560 specific cases. It didn't identify any of the taxpayers involved.
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U.S. and Europe Must Set Example in Push for Global Transparency, Report Says


The U.S. and Europe must eliminate the secrecy havens in their own backyards before they can force other financial centers to complywith global transparency standards, according to a report by Nobel Prize-winning economist Joseph Stiglitz and Swiss anti-corruption expert Mark Pieth.
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Donald Trump's plan to cut US corporation tax 'could impact on Northern Ireland jobs'


One of Donald Trump's economic advisors has cautioned that a cut in the US corporate tax rate could have an impact on Northern Ireland jobs. Mr Trump plans to slash the US rate from 35% to 15% to get manufacturers to movework to the United States.
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House GOP grapples with cross-border tax proposal


The Houseways and Means Committee is grapplingwith how to ensure that a Republican tax reform plan doesn't run afoul ofworld Trade Organization (WTO) agreements, according to a top GOP committee aide on Monday.
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EU Parliament May Lose Right to Veto Public Tax Reporting


Bloomberg

byJoe Kirwin(Bloomberg BNA)

The European Parliament risks losing the right to veto plans to make multinational companies publish tax and profit details for the countries inwhich they operate, according to the European Union's legal advisers.
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Switzerland and Austria will terminate withholding tax agreement


Thewithholding tax (WHT) agreement between Switzerland and Austriawill be terminated on January 1, 2017, the Swiss authorities have announced, and the UK'swHT treatywith Switzerland also faces the same fate.
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Tax Reform in the Next Congress


It is clear that the next Congress and President-elect Trump very likelywill to try to do corporate tax reform ÔøΩ particularly international tax reform. Among the reasons this is the case is that there is an emerging consensus among both parties from a policy perspective that improving the business tax code could make America more competitive.
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Tax Revenues Rising Since Financial Crisis, EU Report Says


Tax revenues have continued to rise since the 2007-2008 financial crisis in most EU member states, and the EU remains a relatively high-tax area, according to a report published November 11 by the European Commission.
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News Analysis: What's on Trump's International Tax Agenda?


Donald Trump's presidentialwin, combinedwith the fact that Republicanswill control both chambers of Congress,will increase the chances for comprehensive tax reform, including on the international side, in 2017. Trump's campaign proposals included several international tax proposals, some consistentwith those introduced by Republican lawmakers and others not.
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Moscovici doesn't rule out U.S. inclusion on tax haven blacklist


European tax czar Pierre Moscovici says no country, including the U.S., should consider itself immune from the tax haven blacklist the European Union is drawing up.
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Trumps Tax-Cut Plans May Draw Congress to Art of the Deal


Businesses and individuals may get major tax breaks if President-elect Donald Trump can successfully meld his own tax proposalswith similar ones favored by House Republicans.
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Exclusive Video: US President-elect Donald Trump's tax plan


International Tax Review

byCaroline Byrne (International Tax Review)

Stephen Moore, economic adviser to President-elect Donald Trump, sat downwith International Tax Review in New York in theweeks before the Republican victory to discuss the details of Trump's tax and trade plans.
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Ireland says Trump plans should not hurt it as multinational hub


byPadraic Halpin (Reuters)

U.S. president-elect Donald Trump's plans to slash corporate tax rates should not keep companies from setting up operations abroad, a move thatwould damage a key plank of Ireland's industrial policy, the Irish finance minister said onwednesday.
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Flawed System Contributes to U.S. Multinationals' Tax Woes


Tax authorities around theworldwill continue targeting U.S. multinationals as long as the corporate tax system permits indefinite deferral of tax on their foreign earnings, according to Robert Stack, Treasury deputy assistant secretary (international tax affairs).
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New International Tax Reporting May Snag Big U.S. Nonprofits


New York University,which has degree-granting campuses in Abu Dhabi and Shanghai, is getting ready for a sweeping international tax reporting requirement. It's surprising, but the university is just one of possibly many nonprofit organizations that may be caught up in an international reporting regime meant to reveal multinational companies' aggressive tax planning.
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A Stranded $2 Trillion Overseas Stash Gets Closer to Coming Home


The next president may have a rare opportunity to close tax loopholes that have let American corporations stash more than $2 trillion in untaxed profits outside the United States.

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"Google tax law" in Russia


According to the new tax regulations in Russia that come into force on January 1, 2017, foreign IT companies that provide services by means of the internet to individuals (not self-employed persons) residing in Russiawill have to pay a value added tax (VAT).
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CCCTB Good for Business, European Commission Paper Says


Despite its cool reception from the international business community, the European Commission's proposal for a common consolidated corporate tax base (CCCTB)would reduce the cost of capital for multinational enterprises, resulting in more investment, higherwages, and economic growth, according to a recentworking paper released by the commission.
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Switzerland Publishes Press Release on Corporate Tax Reform Package


by Jessica Silbering-Meyer
On October 27, 2016, the Swiss Federal Council published a press release in support of the Corporate Tax Reform (CTR) III package. CTR IIIwas approved by Parliament in June 2016, andwill be subject to a public referendum on February 12, 2017.
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With Apple Ruling, European Commission Draws First Blood In Global Tax War


by Joe Harpaz
In case you missed it, thewriting has officially been spray-painted on thewalls of government corridors around theworld: tax authorities are coming for big business, even if it means stirring new conflictwith one another. The latest and most visible example of this, of course, has been the European Commission ruling against Apple this past August,which found that Ireland granted undue tax benefits of up to ÔøΩ13 ($14.5) billion to Apple.
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Inversion Benefits May Take 17 Years With Debt-Equity Rules


If a corporationwere to move its tax home overseas through an inversion, it might now have towait 17 years to realize the tax benefits it could reap previously through earnings-stripping transactions, two tax lawyers said.

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