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Recent OECD Guidance on Minimum Tax Aligns With EU Tax Rule

  • By Stephen Gardner

The European Union reaffirmed its support for the international two-pillar tax deal and confirmed recent guidance on the global minimum tax aligns with the EU’s implementation of the rule, according to a statement issued by finance ministers.

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Barbados to Adopt Pillar 2 Domestic Minimum Tax in 2024

  • By Stephanie Soong

The Barbados government will implement a domestic minimum top-up tax aligned with pillar 2 global minimum tax rules as part of a plan to overhaul its corporate tax system, according to Prime Minister Mia Mottley.

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The End of the Brazilian Interest on Equity Benefit?

  • By Maria Bel, Luis Vargas, and Paulo Vellano

Multinational groups with presence in Brazil should analyze the tax profile of their Brazilian entities in view of the potential elimination of the long-standing interest on equity tax deduction.

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Brazil Tackles One of World’s Most Complicated Tax Codes

  • By Martha Beck and Daniel Carvalho

Brazil’s senate approved a reform to simplify one of the world’s most byzantine tax codes.

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Countries’ Tax Info Needs To Be Made More Available, Forum Says

  • By Danish Mehboob

An international agency monitoring tax transparency reported most of its member countries are complying with tax information exchange standards, but the availability of certain information can be improved.

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FTC Pillar 2 Guidance and Relief Extension to Be Issued Together

  • By Amanda Athanasiou

An IRS official has confirmed that the agency still plans to release foreign tax credit guidance on pillar 2 by year-end and expects to extend temporary relief from final FTC rules at the same time.

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Lavish Tax Credits and Trade Protections Lure Solar Firms to U.S.

  • By Ana Swanson
  • By Jim Tankersley

A combination of government policies is finally succeeding in reversing a long decline in solar manufacturing in the United States.

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Possible Foreign Tax Credit Fix to Come After Minimum Tax Guidance

  • By Michael Rapoport

The IRS plans to go ahead with guidance on how foreign tax credit regulations interact with the new global minimum tax even though it’s still considering whether and how those regulations might be modified, an IRS official said Monday.

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Ship Has Sailed on Pillar 2, EU Committee Warns U.S. Congress

  • By Stephanie Soong

Implementation of global minimum tax rules is happening, and there’s nothing the United States can do to stop it, members of the European Parliament subcommittee on tax matters told U.S. lawmakers.

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Italy Adopts Novel Pillar 2 Dispute Resolution Measure

  • By Stephanie Soong

Italy has introduced an innovative dispute prevention and resolution provision based on the principle of reciprocity as part of its pillar 2 implementation strategy, according to a finance ministry official.

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U.S. Economist Defends IRA Against Calls for Carbon Tax

  • By Amanda Athanasiou

A White House economist has responded to ExxonMobil’s support for a carbon tax by casting serious doubt on the possibility of achieving a global harmonized carbon market without any climate policy deviations.

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Jamaica Plans Domestic Top-Up Tax in Minimum Tax Implementation

  • By Michael Rapoport

Jamaica plans on establishing a qualified domestic minimum top-up tax as part of its implementation of the pending global minimum tax, a Jamaican official said Tuesday.

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US Envoy Warns of Big Fight If Canada Digital Tax Takes Effect

  • By James Munson

The US and Canada are headed toward a “big fight” over Canada’s plans to enact a digital services tax unless a solution is found, US Ambassador David Cohen said Tuesday.

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U.S. Looks to Allay European Fears of a Subsidy War

  • By Alan Rappeport

Wally Adeyemo, the deputy Treasury secretary, said the United States was continuing to look for ways to improve coordination with Europe on climate and energy security initiatives.

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Treasury Wants Different Pillar 2 Treatment for Research Credit

  • By Sarah Paez

The United States considers the treatment of the nonrefundable research credit by the pillar 2 global minimum tax regime an important priority as countries begin to implement the legislation, a Treasury official said.

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Argentina to Push Withholding Tax Absent Pillar 1 Progress

  • By Stephanie Soong

Argentina will be ready to present a proposal for a withholding tax mechanism on digital service providers if progress isn’t made soon on the signing of a multilateral convention implementing pillar 1, an Argentine official said.

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A Global Conversation on the Amount B Discussion Draft

  • By Oliver Treidler

Oliver Treidler explains the structure of the OECD’s amount B and reviews its discussion draft comments and suggestions submitted by many industry participants.

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Treasury Applauds OECD Draft Treaty But Sees More Work Ahead

  • By Michael Rapoport

A draft treaty that would implement a key part of the OECD’s global tax agreement represents “significant progress,” but work remains to be done, a Treasury Department official said Monday.

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German MOF at Odds With OECD Over Intangibles Pricing

  • By Alexander F. Peter

The pricing of intangibles in related-party transactions will cause unsolvable disputes unless the OECD provides revised guidance, according to panelists at the annual Congress of the International Fiscal Association in Cancun, Mexico.

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Bulgaria's Minimum Tax Must Have Substance Carveout, NFTC Says

  • By Stephanie Soong

If Bulgaria doesn’t join other EU member states in including a substance-based carveout in its proposed domestic minimum top-up tax, it will damage its ability to attract foreign investment, a trade group warned.

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Plowgian Asks Taxpayers to Tell Treasury What MLC Draft Got Wrong

  • By Andrew Velarde

A senior Treasury official is offering greater detail on what public input the department is seeking in response to the amount A multilateral convention under pillar 1, including comments on what the draft document got wrong.

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Puerto Rico Explores Global Minimum Tax, Talks With Industry

  • By Angélica Serrano-Román

Puerto Rico is taking steps to be part of the global corporate tax deal’s minimum tax plan, island Treasury Secretary Francisco Parés Alicea said as he moved between meetings in Washington and New York this week to discuss the prospects with companies with a large presence in the local economy.

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Reform US International Taxation Laws to Set a Global Example

  • By Philip G. Cohen

Some recent developments should spur action by Congress to reform US tax laws that address international taxation. Congress did this in 2017 but in an ill-conceived way, and it should be revamped.

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Developing Countries Helped to Build Two-Pillar Plan, OECD Says

  • By Elodie Lamer

During a debate at the EU’s annual tax symposium about the advantages of the OECD's global tax reform plan versus a U.N. tax convention, the OECD said developing countries helped to shape its tax pillars.

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Firms Will Struggle With Pillar 2 and BEFIT, Business Rep Says

  • By Stephanie Soong

Global minimum tax rules and a common EU corporate tax system will likely overload companies’ capacity for compliance because the interplay between the regimes could be overly complex, a business representative warned.

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Netherlands Urged to Seek Alternatives if Pillar 1 Tax Deal Fails

  • By Stephanie Soong

The Netherlands should consider other options in case countries can’t reach agreement soon on the amount A multilateral treaty under pillar 1 of the two-pillar global tax reform plan, a Dutch tax official told parliament.

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U.S. Claims Court Allows Foreign Tax Credit for NII Tax Liability

  • By Michael Smith

The Court of Federal Claims has allowed a U.S. couple residing in France to use the France-U.S. tax treaty to claim a foreign tax credit against their net investment income tax liability.

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A Tax Rule Change Is Threatening the Survival of Some Businesses

  • By Jennifer Williams-Alvarez

Businesses large and small are being hit by a change in tax rules on R&D expenses. Some are struggling to stay afloat.

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OECD Weighing Pillar 2 Deferred Tax Asset Guidance

  • By Sarah Paez
  • By Stephanie Soong

The inclusive framework on base erosion and profit shifting is considering issuing pillar 2 guidance on the treatment of deferred tax assets in jurisdictions with federal and subnational taxes, an OECD official said.

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Tax Concessions Undermine Pillar 2 Tax Rules, EU Study Says

  • By Stephanie Soong

An initial projected revenue increase under pillar 2 global minimum tax rules has diminished because of negotiated concessions like a substance-based carveout and generous treatment of tax credits, according to a sweeping EU study.

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NGOs Criticize EU's Reluctance to Join a U.N. Tax Convention

  • By Elodie Lamer

Nongovernmental organizations have expressed disappointment regarding the EU’s hesitancy about joining a legally binding U.N. tax convention, but EU officials said they believe it would duplicate and could undermine the OECD’s work.

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Multilateralism Crisis Mustn't Spread to Tax, Colombian Adviser Says

  • By Stephanie Soong

Disagreements between the global north and south and debates over whether the U.N. or OECD should lead on tax matters could cause a breakdown in multilateral tax cooperation, a Colombian government adviser warned.

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An Amount B for Developing Countries

  • By Suranjali Tandon
  • By Chetan Rao

Suranjali Tandon and Chetan Rao explain the potential importance of amount B for developing countries and suggest ways that amount B can be improved to address specific developing country needs.

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IRS Heightens Scrutiny of Foreign, Large Corporations


Amplifying its efforts to go after tax dodgers, the IRS Friday announced new efforts to target foreign corporations and the largest corporate taxpayers.

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European Parliament Report Addresses Excess Profits, Inflation

  • By Elodie Lamer

In their compromise report on the role of tax policy in times of crisis, members of the European Parliament have called for a broader excess profits tax net and inflation-adjusted personal income tax brackets.

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Five EU Member States Pursuing Delayed Pillar 2 Implementation

  • By Cady Stanton

Five EU member states have told the European Commission that they plan to avail of the possibility to delay implementation of the pillar 2 directive, a top EU tax official said.

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Bipartisan Taiwan Tax Bill Text Issued by Congress’s Tax Writers

  • By Chris Cioffi

Senate and House tax-writers seeking to encourage cross-border business collaboration between Taiwan and the US released bipartisan bill text Thursday outlining their plan to provide treaty-like benefits through the tax code.

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Ireland Proposes Draft Minimum Tax Rule with Safe Harbor

  • By Stephen Gardner

Ireland released a Treasury bill Thursday with details of its plans to roll out the global minimum tax, a part of the OECD-led global tax deal.

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U.N. Negotiating Draft Resolution on International Tax Convention

  • By Sarah Paez

The United Nations is negotiating a draft resolution to establish a legally binding convention to promote inclusivity for developing countries in international tax cooperation.

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Delegates Push Back on U.N. Work on Pillar 2 and Tax Incentives

  • By Stephanie Soong

The U.N. shouldn’t pursue further work on the potential effects of global minimum tax rules on tax incentives in the extractives industry because it would be inappropriate, several tax committee delegates said.

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Canada’s Digital Services Tax Projected to Raise C$7.2B by 2028

  • By Brian Platt

Canada’s proposed tax on big technology firms could raise as much as C$7.2 billion ($5.3 billion) over five fiscal years, according to a new projection from a parliamentary spending watchdog.

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Treasury Mulls More US Guidance on Global Minimum Tax Issues

  • By Michael Rapoport

The Treasury Department is working on a potential “next push of guidance” on how the US will reconcile some issues relating to the new global minimum tax, a department official said Tuesday.

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Nigeria Files Resolution to Work Toward UN Global Tax Convention

  • By Michael Rapoport

Nigeria filed a draft resolution calling for the United Nations to create an international tax convention, the next step toward the organization potentially assuming a greater role in global tax cooperation.

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EU Adds Three Tax Haven Countries, Cuts Three From Watchlist

  • By Stephen Gardner

European Union finance ministers Tuesday approved an update to the bloc’s list of jurisdictions considered uncooperative on tax, adding three and removing three, leaving the list with 16 entries.

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Works on Pillar 1 Convention Issues to Run Into 2024, Yellen Says

  • By Stephanie Soong
  • By Alexander Rifaat

U.S. Treasury Secretary Janet Yellen indicated countries will work into 2024 to settle issues preventing the signing of the pillar 1 multilateral convention, which would mean a related digital tax freeze will soon expire.

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Global Reallocation Tax Rules Can Be Simplified Later, OECD Says

  • By Danish Mehboob

Computations to reallocate taxing rights to markets under a global treaty might be simplified over time, according to one senior official from the OECD.

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US to Miss Deadline to Avoid Fresh Digital Taxes, Yellen Says

  • By William Horobin and Christopher Condon

Treasury Secretary Janet Yellen indicated the US will be unable to sign a treaty on global tax rules in time to uphold a deal that prevents other countries from imposing new levies on some of the largest American tech companies.

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Pillar 2, State Aid, and Industrial Policy

  • By Mindy Herzfeld

Mindy Herzfeld explains that the OECD will likely find itself policing a wider range of state subsidies as countries look for creative ways to shore up investment while staying on the right side of pillar 2.

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Tax Chiefs Vow to Deepen Cooperation on Global Minimum Tax Rules

  • By Stephanie Soong

Representatives of more than 40 members of the Forum on Tax Administration have pledged to facilitate the administration of global minimum tax rules by cooperating on compliance issues like risk assessment.

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Is the UTPR a 100 Percent Tax on a Deemed Distribution?

  • By Fadi Shaheen

Fadi Shaheen floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by the UTPR entity, and he addresses questions that would follow regarding the desirability of such a confiscatory tax and its interaction with tax treaties.

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