Int'l Tax News
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OECD unveils global crackdown on tax arbitrage by multinationals
by Vanessa Houlder (Financial Times)
Plans for a global crackdown on tax arbitrage markinga turning point in the history of international co-operation on taxationwere unveiled on Friday at the meeting of G20 finance ministers in Moscow.
Thewide-ranging action plan on tacklingbase erosion and profits shifting has been drawn up by the Paris-based Organisation for Economic Co-operation and Development for the G20 in response to sustained criticism of the low tax rates paid by some multinational companies such as Google.
Pascal Saint-Amans, the top tax official at the OECD, said the initiativewould force up tax rates for multinationals that organise their affairs so they paid little tax. He said:They know the golden age ofwe dont pay taxes anywhere is over.
For the story, go here.
Plans for a global crackdown on tax arbitrage markinga turning point in the history of international co-operation on taxationwere unveiled on Friday at the meeting of G20 finance ministers in Moscow.
Thewide-ranging action plan on tacklingbase erosion and profits shifting has been drawn up by the Paris-based Organisation for Economic Co-operation and Development for the G20 in response to sustained criticism of the low tax rates paid by some multinational companies such as Google.
Pascal Saint-Amans, the top tax official at the OECD, said the initiativewould force up tax rates for multinationals that organise their affairs so they paid little tax. He said:They know the golden age ofwe dont pay taxes anywhere is over.
For the story, go here.
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America Goes It Alone on High Corporate Taxes
by Mieko Nakabayashi and James Carter (Wall Street Journal)
What happenswhen the international economy changes but tax policy does not? That is a central question facing the United States and Japan,which have the highest corporate tax rates in the industrializedworld. The need for action is acute, and emerging trends in global commerce demonstrate the need for tax policies that alignwith those trends.
A recent analysis by Thomson Reuters of business acquisitions showed that at least 484 U.S. firms,with a value of more than $43.6 billion, have been acquired by foreign interests this year alone. One factor in these acquisitions is the differentways inwhich nations impose corporate income taxes.
When a company is sold, the price is established by myriad factors, one ofwhich is the tax structure facing the buyer. Corporations based in countrieswith taxes lower than in the U.S. can offer a higher price because of a smaller tax liability after acquiring the new firm. Inwhich countries do companies have the built-in advantage over American firms in a bidding process? The answer is simple. All of them.
For the story, go here.
What happenswhen the international economy changes but tax policy does not? That is a central question facing the United States and Japan,which have the highest corporate tax rates in the industrializedworld. The need for action is acute, and emerging trends in global commerce demonstrate the need for tax policies that alignwith those trends.
A recent analysis by Thomson Reuters of business acquisitions showed that at least 484 U.S. firms,with a value of more than $43.6 billion, have been acquired by foreign interests this year alone. One factor in these acquisitions is the differentways inwhich nations impose corporate income taxes.
When a company is sold, the price is established by myriad factors, one ofwhich is the tax structure facing the buyer. Corporations based in countrieswith taxes lower than in the U.S. can offer a higher price because of a smaller tax liability after acquiring the new firm. Inwhich countries do companies have the built-in advantage over American firms in a bidding process? The answer is simple. All of them.
For the story, go here.
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G-20 Backs Plan to Curb Tax Avoidance by Large Corporations
by Andrew E. Kramer & Floyd Norris (New York Times)
Theworld's richest economies for the first time endorsed a blueprint on Friday to curbwidely used tax avoidance strategies that allow some multinational corporations to pay only a pittance in income taxes.
It could be years before any changes take place in national tax laws and big corporations and other interest groups are sure to lobby heavily to preserve their tax breaks. But the proposalwas the most concrete response yet to the intensifying pressure on governments around theworld to address the issue.
For the story, go here.
Theworld's richest economies for the first time endorsed a blueprint on Friday to curbwidely used tax avoidance strategies that allow some multinational corporations to pay only a pittance in income taxes.
It could be years before any changes take place in national tax laws and big corporations and other interest groups are sure to lobby heavily to preserve their tax breaks. But the proposalwas the most concrete response yet to the intensifying pressure on governments around theworld to address the issue.
For the story, go here.
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G-20 to target global tax loopholes
by Howard Schneider (Washington Post)
Topworld economic officials are expected to agree thisweekend on a major push to tighten global tax laws, touching offwhat could be a sensitive debate as nations vie to protect their favored industries and maintain tax breaks they've used to court investment.
In theory, the 40-pagework plan to be endorsed by the Group of 20 economic powers in Moscow is about shaping the international tax system so it reflects how global companies now operate - and ensures that the Apples and Amazons pay a fairer share of tax in the nationswhere they do business.
But the more detailed discussion thatwill follow over the next two years or so, as countries try to develop changes to tax laws and treaties, could take on far more political tones.
For the story, go here.
Topworld economic officials are expected to agree thisweekend on a major push to tighten global tax laws, touching offwhat could be a sensitive debate as nations vie to protect their favored industries and maintain tax breaks they've used to court investment.
In theory, the 40-pagework plan to be endorsed by the Group of 20 economic powers in Moscow is about shaping the international tax system so it reflects how global companies now operate - and ensures that the Apples and Amazons pay a fairer share of tax in the nationswhere they do business.
But the more detailed discussion thatwill follow over the next two years or so, as countries try to develop changes to tax laws and treaties, could take on far more political tones.
For the story, go here.
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G-20 Nations Fully Endorse OECD Action Plan on Tax Evasion
by Theophilos Argitis & Scott Rose
Group of 20 nationsfully endorse the ambitious and comprehensive plan presented by the Organization for Economic Cooperation and Development, according to a statement published in Moscow today.
“Ensuring that all taxpayers pay their fair share of taxes is a high priority in the context of fiscal sustainability, promoting growth and the needs of developing countries to build capacity for financing development, the G-20 said after a two-day meeting of finance chiefs.
For the story, go here.
Group of 20 nationsfully endorse the ambitious and comprehensive plan presented by the Organization for Economic Cooperation and Development, according to a statement published in Moscow today.
“Ensuring that all taxpayers pay their fair share of taxes is a high priority in the context of fiscal sustainability, promoting growth and the needs of developing countries to build capacity for financing development, the G-20 said after a two-day meeting of finance chiefs.
For the story, go here.
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Treasury Officials Set Expectations for BEPS Action Plan
by David D. Stewart (Tax Analysts, Tax Notes Today)
Treasury officials on July 22 attempted to allay fears about the scope of the OECD's base erosion and profit shifting (BEPS) action plan by stressing that recommended changes to the international tax systemwould be incremental and targeted at unintended consequences of the current system.
Speaking during a Deloittewebcast on the recently released BEPS action plan, Henry Louie, deputy to the Treasury international tax counsel for treaty affairs, said the United States does not see the BEPS project as a "wholesale rethinking of international tax principles" but rather as a targeted approach to areas of international taxation that don'twork as designed.
For the story, go here. (Subscription required)
Treasury officials on July 22 attempted to allay fears about the scope of the OECD's base erosion and profit shifting (BEPS) action plan by stressing that recommended changes to the international tax systemwould be incremental and targeted at unintended consequences of the current system.
Speaking during a Deloittewebcast on the recently released BEPS action plan, Henry Louie, deputy to the Treasury international tax counsel for treaty affairs, said the United States does not see the BEPS project as a "wholesale rethinking of international tax principles" but rather as a targeted approach to areas of international taxation that don'twork as designed.
For the story, go here. (Subscription required)
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G-20 Finance Ministers Endorse OECD Action Plan on BEPS and Automatic Information Exchange
by Kristen A. Parillo (Tax Analysts, Tax Notes Today)
G-20 finance ministers and central bank governors on July 20 said they "fully endorse" the OECD's action plan on base erosion and profit shifting (BEPS) aswell as the OECD's proposed global model for multilateral and bilateral information exchange.
In a communiqué released at the conclusion of their July 19-20 meeting in Moscow, the finance ministers and central bank governors said that ensuring that all taxpayers pay their fair share of taxes is a high priority in the context of fiscal sustainability, economic growth, and the needs of developing countries. "Tax avoidance, harmful practices and aggressive tax planning have to be tackled," theywrote.
The G-20 meeting participants expressed their approval of the "ambitious and comprehensive" BEPS action plan presented to them by the OECD on July 19.
For the story, go here. (Subscription required)
G-20 finance ministers and central bank governors on July 20 said they "fully endorse" the OECD's action plan on base erosion and profit shifting (BEPS) aswell as the OECD's proposed global model for multilateral and bilateral information exchange.
In a communiqué released at the conclusion of their July 19-20 meeting in Moscow, the finance ministers and central bank governors said that ensuring that all taxpayers pay their fair share of taxes is a high priority in the context of fiscal sustainability, economic growth, and the needs of developing countries. "Tax avoidance, harmful practices and aggressive tax planning have to be tackled," theywrote.
The G-20 meeting participants expressed their approval of the "ambitious and comprehensive" BEPS action plan presented to them by the OECD on July 19.
For the story, go here. (Subscription required)
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The Taxation of Cloud Computing and Digital Content
by David J. Shakow (Tax Analysts, Tax Notes Today)
In this report, Professor David J. Shakow describes the problems cloud computing poses for tax systems. He shows how current law is applied to cloud computing and identifies the difficulties in doing so.
For the report, go here. (Subscription required)
In this report, Professor David J. Shakow describes the problems cloud computing poses for tax systems. He shows how current law is applied to cloud computing and identifies the difficulties in doing so.
For the report, go here. (Subscription required)
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Joint Action for Efficient and Fair Taxation
by Angel Gurria (Secretary-General of the OECD)
OECD Secretary-General Angel Gurría addressed the G-20 finance ministers' meeting in Moscow on July 20, touting the OECD's base erosion and profit shifting action plan and automatic information exchange proposal as solutions to factors that undermine the fairness and integrity of global tax systems.
For the speech, go here.
OECD Secretary-General Angel Gurría addressed the G-20 finance ministers' meeting in Moscow on July 20, touting the OECD's base erosion and profit shifting action plan and automatic information exchange proposal as solutions to factors that undermine the fairness and integrity of global tax systems.
For the speech, go here.
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Nuts & Bolts of Corporate Tax Reform
by Stevewamhoff (Citizens for Tax Justice)
Lawmakers should repeal deferral of taxes on corporations' offshore profits and reject proposals for a territorial tax system or repatriation holiday to increase revenue from progressive sources, Citizens for Tax Justice said in a July 19 presentation on corporate tax reform.
For the presentation, go here. (Subscription required)
Lawmakers should repeal deferral of taxes on corporations' offshore profits and reject proposals for a territorial tax system or repatriation holiday to increase revenue from progressive sources, Citizens for Tax Justice said in a July 19 presentation on corporate tax reform.
For the presentation, go here. (Subscription required)
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It's not just Google...
by Tom Bergin
More than half the top U.S. tech firms minimise tax bills by using structures that some governmentswant to change. Itwon't be easy.
For the report, go here.
More than half the top U.S. tech firms minimise tax bills by using structures that some governmentswant to change. Itwon't be easy.
For the report, go here.
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Transfer Pricing: Going Past' Arm's Length Standard Means Recognizing Economic Reality,' Official Says
by Deloresw. Gregory (Bloomberg Daily Tax Report)
The Organization for Economic Cooperation and Development's assertion that it mightgo beyond the arm's length principle in its bid to fix international transfer pricing rules does not mean that it has embraced a formulary approach, a U.S. Treasury Department official said July 22.
For the story, go here. (Subscription required)
The Organization for Economic Cooperation and Development's assertion that it mightgo beyond the arm's length principle in its bid to fix international transfer pricing rules does not mean that it has embraced a formulary approach, a U.S. Treasury Department official said July 22.
For the story, go here. (Subscription required)
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A Global Revenue Grab: The G-20 unveils a plan to limit international tax competition. .
bywall Street Journal
After five years of failing to spur a robust economic recovery through spending and tax hikes, theworld's richest countries have hit upon a new idea that looks a lot like the old: International coordination to raise taxes on business.
The Organization for Economic Cooperation and Development on Friday presented its action plan to combatwhat it calls "base erosion and profit shifting," or BEPS. This is bureaucratese for not paying as much tax as governmentwishes you did. The plan bemoans the danger of "double non-taxation,"whatever that is, and even raises the specter of "global tax chaos" if this bogeyman called BEPS isn't tamed.
For the editorial, go here.
After five years of failing to spur a robust economic recovery through spending and tax hikes, theworld's richest countries have hit upon a new idea that looks a lot like the old: International coordination to raise taxes on business.
The Organization for Economic Cooperation and Development on Friday presented its action plan to combatwhat it calls "base erosion and profit shifting," or BEPS. This is bureaucratese for not paying as much tax as governmentwishes you did. The plan bemoans the danger of "double non-taxation,"whatever that is, and even raises the specter of "global tax chaos" if this bogeyman called BEPS isn't tamed.
For the editorial, go here.
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BEPS Project Has Consequences for U.S. Tax Treaties
by Jeremiah Coder
The OECD's newly released action plan to combat base erosion and profit shifting (BEPS)will have an impact on treaty issues as the United Statesworks to update existing treaty agreements and enter into new ones, Arlene Fitzpatrick, attorney-adviser in the Treasury Office of International Tax Counsel, said July 24.
For the story, go here. (Subscription required)
The OECD's newly released action plan to combat base erosion and profit shifting (BEPS)will have an impact on treaty issues as the United Statesworks to update existing treaty agreements and enter into new ones, Arlene Fitzpatrick, attorney-adviser in the Treasury Office of International Tax Counsel, said July 24.
For the story, go here. (Subscription required)
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IRS Economist Discusses Challenges of Intangibles in Transfer Pricing
by Matthew R. Madara
The difficulty the IRS has had in resolving transfer pricing issues involving intangibles is chiefly because of the Tax Court's decision in Veritas Software Corp. v. Commissioner, 133 T.C. 297 (2009), according to Bill Morgan, senior economic adviser (transfer pricing operations), IRS Large Business and International Division.
For the story, go here. (Subscription required)
The difficulty the IRS has had in resolving transfer pricing issues involving intangibles is chiefly because of the Tax Court's decision in Veritas Software Corp. v. Commissioner, 133 T.C. 297 (2009), according to Bill Morgan, senior economic adviser (transfer pricing operations), IRS Large Business and International Division.
For the story, go here. (Subscription required)
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Transfer Pricing: OECD Action Plan Raises Questions About Scope, Timing of Consensus on BEPS
by Deloresw. Gregory, Rick Mitchell & Kevin A. Bell (Bloomberg Daily Tax Report)
An action plan for dealingwith base erosion announced by the Organization for Economic Cooperation and Development July 19 has raised a number of questions among practitioners in the United States and abroadwho are concerned about assertions the plan mightgo beyond the arm's-length principle in a bid to fix international transfer pricing rules.
For the report, go here.
An action plan for dealingwith base erosion announced by the Organization for Economic Cooperation and Development July 19 has raised a number of questions among practitioners in the United States and abroadwho are concerned about assertions the plan mightgo beyond the arm's-length principle in a bid to fix international transfer pricing rules.
For the report, go here.
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The OECD's BEPS report: How did others react?
by Matthew Gilleard (ITR)
Now the dust from lastweek's G20 finance ministers meeting in Moscow is beginning to settle, the question is towhat extent the OECD's action plan for tackling base erosion and profit shifting (BEPS) marks a turning point in the history of international taxation, andwhether the timeframes outlined in the report are realistic.
For the story, go here.
Now the dust from lastweek's G20 finance ministers meeting in Moscow is beginning to settle, the question is towhat extent the OECD's action plan for tackling base erosion and profit shifting (BEPS) marks a turning point in the history of international taxation, andwhether the timeframes outlined in the report are realistic.
For the story, go here.
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Practitioners Air Concerns About OECD's BEPS Action Plan
by Kristen A. Parillo & Stephanie Soong Johnston
The OECD's newly released action plan to combat base erosion and profit shifting (BEPS) is ambitious but rifewith challenges for both multinationals and governments, practitioners at PricewaterhouseCoopers LLP and Ernst & Young LLP said July 23.
During separatewebcasts hosted by PwC and E&Y, practitioners from those firms' U.S. and international offices discussed the implications of the action plan for multinational enterprises and tax authorities. The OECD presented the plan,which identifies 15 actions it says should be undertaken by countries in a coordinated manner to address the sources of BEPS, to the G-20 finance ministers at their July 19-20 meeting in Moscow. In a communiqué released at the conclusion of the meeting, the finance ministers said they "fully endorse" the action plan.
For the story, go here. (Subscription required)
The OECD's newly released action plan to combat base erosion and profit shifting (BEPS) is ambitious but rifewith challenges for both multinationals and governments, practitioners at PricewaterhouseCoopers LLP and Ernst & Young LLP said July 23.
During separatewebcasts hosted by PwC and E&Y, practitioners from those firms' U.S. and international offices discussed the implications of the action plan for multinational enterprises and tax authorities. The OECD presented the plan,which identifies 15 actions it says should be undertaken by countries in a coordinated manner to address the sources of BEPS, to the G-20 finance ministers at their July 19-20 meeting in Moscow. In a communiqué released at the conclusion of the meeting, the finance ministers said they "fully endorse" the action plan.
For the story, go here. (Subscription required)
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Letter to U.S. Senators on Baucus-Hatch Tax Reform Plan
by Louis R. Chenevert, Chair, Tax & Fiscal Policy Cmte, Business Roundtable
Revenue-neutral tax reform that promotes economic growth and job creation can be accomplished by cutting the corporate tax rate to 25 percent, shifting to a territorial tax system, and reforming corporate tax expenditures, the Business Roundtable said in a July 22 letter to senators.
For the letter, go here.
Revenue-neutral tax reform that promotes economic growth and job creation can be accomplished by cutting the corporate tax rate to 25 percent, shifting to a territorial tax system, and reforming corporate tax expenditures, the Business Roundtable said in a July 22 letter to senators.
For the letter, go here.
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Tax Evasion: Practitioners: OECD's BEPS Action Plan Could Have Big Consequences for Multinationals
by Lydia Beyoud (Bloomberg, Daily Tax Report)
Multinational corporations mustwait until the Organization for Economic Cooperation and Development's issues country-specific recommendations on changes to domestic rules related to base erosion and profit shifting activities before they can fully evaluate how theywill be impacted by the BEPS action plan, a practitioner said July 23.
“Once the OECD recommendations have been made, itwill be for the individual countries to decidewhether,when, and how to implement the recommendations, Mat Mealey, leader of Ernst & Young's International Tax Services in the United Kingdom and Ireland, said during awebinar sponsored by E&Y.
For the story, go here. (Subscription required)
Multinational corporations mustwait until the Organization for Economic Cooperation and Development's issues country-specific recommendations on changes to domestic rules related to base erosion and profit shifting activities before they can fully evaluate how theywill be impacted by the BEPS action plan, a practitioner said July 23.
“Once the OECD recommendations have been made, itwill be for the individual countries to decidewhether,when, and how to implement the recommendations, Mat Mealey, leader of Ernst & Young's International Tax Services in the United Kingdom and Ireland, said during awebinar sponsored by E&Y.
For the story, go here. (Subscription required)
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Multinational Corporations: Changing Headquarters Landscape 2000-2012: Corporate Taxation and the Impact of Emerging Market Economies
by Thomas Kinrade and Tom Neubig (Bloomberg, Daily Tax Report)
The international business landscape, once dominated by multinational corporations from a few developed economies, is nowwell represented by corporations from both established and emerging economies.
In fact, as the gross domestic product levels of emerging markets have grown, so too has the number of companieswith headquarters in these countries. Over approximately the past decade, the share of theworld's largest companieswith headquarters in emerging markets has more than quintupled, from 4 percent in 2000 to 22 percent in 2012.
While the increase in company headquarters locations in emerging markets can be attributed in part to the growth of economies in those regions, the evidence suggests that, in today's competitive international business landscape, tax policy continues to play an important role.
For the report, go here. (Subscription required)
The international business landscape, once dominated by multinational corporations from a few developed economies, is nowwell represented by corporations from both established and emerging economies.
In fact, as the gross domestic product levels of emerging markets have grown, so too has the number of companieswith headquarters in these countries. Over approximately the past decade, the share of theworld's largest companieswith headquarters in emerging markets has more than quintupled, from 4 percent in 2000 to 22 percent in 2012.
While the increase in company headquarters locations in emerging markets can be attributed in part to the growth of economies in those regions, the evidence suggests that, in today's competitive international business landscape, tax policy continues to play an important role.
For the report, go here. (Subscription required)
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New OECD Report on Tax Avoidance Lags Behind Global Transparency Movement
by Tom Cardamone (GFI)
Global Financial Integrity on July 19 criticized the OECD action plan addressing base erosion and profit shifting, presented at the G-20 finance ministers' meeting in Moscow, saying that it does not "fully embrace" country-by-country reporting for multinationals and calling on the G-20 to endorse a disaggregated accounting standard.
For the GFI response, go here.
Global Financial Integrity on July 19 criticized the OECD action plan addressing base erosion and profit shifting, presented at the G-20 finance ministers' meeting in Moscow, saying that it does not "fully embrace" country-by-country reporting for multinationals and calling on the G-20 to endorse a disaggregated accounting standard.
For the GFI response, go here.
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Levin statement on OECDs offshore tax action plan
from Senator Carl Levin (D-Mich)website
An Organisation for Economic Cooperation and Development report on stopping offshore profit shifting indicates "growing global demand for reining in corporate offshore tax abuses," said Sen. Carl Levin, D-Mich., chair of the Senate Homeland Security and Governmental Affairs Permanent Subcommittee on Investigations, in a July 19 statement.
For the release, go here.
An Organisation for Economic Cooperation and Development report on stopping offshore profit shifting indicates "growing global demand for reining in corporate offshore tax abuses," said Sen. Carl Levin, D-Mich., chair of the Senate Homeland Security and Governmental Affairs Permanent Subcommittee on Investigations, in a July 19 statement.
For the release, go here.
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OECD Action Plan on Base Erosion and Profit Shifting Draws Mixed Reactions
by Stephanie Soong Johnston & David D. Stewart (Tax Analysts, Tax Notes)
The OECD's highly anticipated action plan on base erosion and profit shifting (BEPS), presented to G-20 finance ministers in Moscow on July 19, received mostly positive reactions from governments, tax practitioners, and business groups but drew sharp criticism from advocacy groups that said the plan failed to address corporate transparency and excluded developing countries.
The action plan identifies 15 specific actions that the OECDwill accomplish by December 2015 in order to give international governments the tools needed to clamp down on corporate tax avoidance, a growing global concern. Actions include examining and addressing the challenges of taxing the digital economy; neutralizing the effects of hybrid mismatch arrangements; curbing treaty abuse; bolstering controlled foreign corporation rules; reevaluating transfer pricing documentation; and requiring taxpayers to disclose any aggressive tax planning strategies they may be using.
International governments, on thewhole,welcomed the OECD's efforts. The U.K. pledged its full support,with Chancellor of the Exchequer George Osborne announcing that HM Treasury, alongwith France and Germany,will provide $400,000 to the OECD to facilitate the action plan's progress.
For the article, go here. (Subscription required)
The OECD's highly anticipated action plan on base erosion and profit shifting (BEPS), presented to G-20 finance ministers in Moscow on July 19, received mostly positive reactions from governments, tax practitioners, and business groups but drew sharp criticism from advocacy groups that said the plan failed to address corporate transparency and excluded developing countries.
The action plan identifies 15 specific actions that the OECDwill accomplish by December 2015 in order to give international governments the tools needed to clamp down on corporate tax avoidance, a growing global concern. Actions include examining and addressing the challenges of taxing the digital economy; neutralizing the effects of hybrid mismatch arrangements; curbing treaty abuse; bolstering controlled foreign corporation rules; reevaluating transfer pricing documentation; and requiring taxpayers to disclose any aggressive tax planning strategies they may be using.
International governments, on thewhole,welcomed the OECD's efforts. The U.K. pledged its full support,with Chancellor of the Exchequer George Osborne announcing that HM Treasury, alongwith France and Germany,will provide $400,000 to the OECD to facilitate the action plan's progress.
For the article, go here. (Subscription required)
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News Analysis: OECD BEPS Action Plan: Trying to Save the System
by Lee A. Sheppard (Tax Analysts, Tax Notes)
The OECD Centre for Tax Policy and Administration released its action plan to dealwith base erosion and profit shifting (BEPS) lastweek. As predicted, it is a multifaceted attempt to shore up the current international consensus of separate company accounting and transfer pricing.
Around here, your correspondent has never had much good to say about the current system,which is moribund and doesn't deliver a fair share of business income tax revenue to affected countries. But the action plan is a good-faith effort to save the current system, andwith it, the OECD's reputation.
For the article, go here. (Subscription required)
The OECD Centre for Tax Policy and Administration released its action plan to dealwith base erosion and profit shifting (BEPS) lastweek. As predicted, it is a multifaceted attempt to shore up the current international consensus of separate company accounting and transfer pricing.
Around here, your correspondent has never had much good to say about the current system,which is moribund and doesn't deliver a fair share of business income tax revenue to affected countries. But the action plan is a good-faith effort to save the current system, andwith it, the OECD's reputation.
For the article, go here. (Subscription required)
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Treasury Official Addresses Foreign Currency/Subpart F Questions
by Lee A Sheppard (Tax Analysts, Tax Notes)
Danielle Rolfes, Treasury's international tax counsel, came to New York to discuss section 988 questions at the International Tax Institute on July 18.with herwere Chip Harter of PricewaterhouseCoopers LLP, Yaron Z. Reich of Cleary Gottlieb Steen & Hamilton LLP, and Michael Farber of Davis Polk &wardwell LLP.
Multinationals' principal risk exposure that requires hedging is foreign currency exposure. The tax rules are not terribly accommodating to their usual practices, as Harter has frequently explained. The IRS is auditing foreign currency issues.
The crux of the problem is that financial accounting permits all sorts of hedges, including balance sheet hedges and hedges of shareholdings, that multinationalswant to be treated as hedges, or at least offsetting items, for tax purposes so they don't have to book tax liabilities.
For the article, go here. (Subscription required.)
Danielle Rolfes, Treasury's international tax counsel, came to New York to discuss section 988 questions at the International Tax Institute on July 18.with herwere Chip Harter of PricewaterhouseCoopers LLP, Yaron Z. Reich of Cleary Gottlieb Steen & Hamilton LLP, and Michael Farber of Davis Polk &wardwell LLP.
Multinationals' principal risk exposure that requires hedging is foreign currency exposure. The tax rules are not terribly accommodating to their usual practices, as Harter has frequently explained. The IRS is auditing foreign currency issues.
The crux of the problem is that financial accounting permits all sorts of hedges, including balance sheet hedges and hedges of shareholdings, that multinationalswant to be treated as hedges, or at least offsetting items, for tax purposes so they don't have to book tax liabilities.
For the article, go here. (Subscription required.)
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News Analysis: A Modest Proposal for Country-by-Country Reporting
by Martin A. Sullivan (Tax Analysts, Tax Notes)
In news analysis, Martin A. Sullivan makes the case for some public disclosure of country-by-country reporting data.
For the article, go here. (Subscription required.)
In news analysis, Martin A. Sullivan makes the case for some public disclosure of country-by-country reporting data.
For the article, go here. (Subscription required.)
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Economic Analysis: Behind the GAO's 12.6 Percent Effective Corporate Rate
by Martin A. Sullivan (Tax Analysts, Tax Notes)
There are as manyways to calculate an effective tax rate as there areways to order coffee at Starbucks. Sowhen you hear reports about an effective tax rate, it can mean a lot of different things. Small changes inwhat may seem obscure details make a big difference. And because effective tax rates arewidely used as summary statistics for tax burdens, details can have important implications for the direction of tax policy.
On July 1 the Government Accountability Office made a lot of headlineswhen it released a study reporting that the average effective corporate tax rate in 2010was only 12.6 percent.
Although it is common knowledge that many U.S. multinationals have used tax planning to substantially reduce their tax bills, the GAO figure is surprisingly low. Other studies typically report average rates in the mid-20s.
Sowhat explains the difference between the GAO's 12.6 percent rate and other studies' rates?
For the article, go here. (Subscription required)
There are as manyways to calculate an effective tax rate as there areways to order coffee at Starbucks. Sowhen you hear reports about an effective tax rate, it can mean a lot of different things. Small changes inwhat may seem obscure details make a big difference. And because effective tax rates arewidely used as summary statistics for tax burdens, details can have important implications for the direction of tax policy.
On July 1 the Government Accountability Office made a lot of headlineswhen it released a study reporting that the average effective corporate tax rate in 2010was only 12.6 percent.
Although it is common knowledge that many U.S. multinationals have used tax planning to substantially reduce their tax bills, the GAO figure is surprisingly low. Other studies typically report average rates in the mid-20s.
Sowhat explains the difference between the GAO's 12.6 percent rate and other studies' rates?
For the article, go here. (Subscription required)
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California State Bar Member and CPA Suggest Clarifying Foreign Tax Credit Rules
by Jenna (Shih) Anderson & Po Han Chen (Tax Analysts, Tax Notes)
Treasury should issue issue clarifying guidance under §¬ß 901(a), 275(a)(4), and 905(c) such that a taxpayer may take a current year deduction (for additional foreign taxes paid that "relate-back" to a deduction year) in a year inwhich the taxpayer has otherwise elected the foreign tax credit, Jenna (Shih) Anderson of the State Bar of California and CPA Po Han Chen recommended in a report. Alternatively, they recommend that the Treasury issue guidance that provides an exception to the relation-back doctrinewhen the taxes "relate-back" to a deduction year.
For the report, go here. (Subscription required.)
Treasury should issue issue clarifying guidance under §¬ß 901(a), 275(a)(4), and 905(c) such that a taxpayer may take a current year deduction (for additional foreign taxes paid that "relate-back" to a deduction year) in a year inwhich the taxpayer has otherwise elected the foreign tax credit, Jenna (Shih) Anderson of the State Bar of California and CPA Po Han Chen recommended in a report. Alternatively, they recommend that the Treasury issue guidance that provides an exception to the relation-back doctrinewhen the taxes "relate-back" to a deduction year.
For the report, go here. (Subscription required.)
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The myth of Corporate America's offshore cash
by Jeanne Sahadi (Yahoo! Finance)
It's a common argument in the debate over corporate taxes: If the top tax rateweren't so high, U.S. multinational companieswould happily bring home the money they have parked offshore.
And doing sowould lead to greater investment in the U.S. economy.
But it's a myth that all the money is "trapped" abroad, said tax expert Edward Kleinbard. And it's not clear just how much of a spur itwould be to the economy if itwere repatriated.
For the story, go here.
It's a common argument in the debate over corporate taxes: If the top tax rateweren't so high, U.S. multinational companieswould happily bring home the money they have parked offshore.
And doing sowould lead to greater investment in the U.S. economy.
But it's a myth that all the money is "trapped" abroad, said tax expert Edward Kleinbard. And it's not clear just how much of a spur itwould be to the economy if itwere repatriated.
For the story, go here.
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French MP releases business tax simplification plan
by Matthew Gilleard (ITR)
The French Ministry of Finance has released a tax simplification plan, authored by politician Thierry Mandon,which could see interaction and cooperation between taxpayers and tax authorities reach new levels.
For the story, go here. (Registration required)
The French Ministry of Finance has released a tax simplification plan, authored by politician Thierry Mandon,which could see interaction and cooperation between taxpayers and tax authorities reach new levels.
For the story, go here. (Registration required)
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Why India is at a critical stage in tax policy development - India Tax Forum 2013
by Ralph Cunningham (ITR)
The Indian economy grew by 5% in 2012. Outstanding by anyone's standards, except China's, but not enough if the countrywants to create prosperity for all of its more than 1 billion citizens.
For the story, go here. (Registration required)
The Indian economy grew by 5% in 2012. Outstanding by anyone's standards, except China's, but not enough if the countrywants to create prosperity for all of its more than 1 billion citizens.
For the story, go here. (Registration required)
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US tax reform road-show up and running; Baucus says 25% rate unlikely
by Matthew Gilleard (ITR)
Dave Camp and Max Baucus, the chairmen of the US two tax-writing committees, have kicked off their bipartisan tax reform road-show (The Simpler Taxes For America Tour) in Minnesota,with Baucus conceding that getting the corporate tax rate down to 25% is a bit of a stretch.
For the story, go here. (Registration required)
Dave Camp and Max Baucus, the chairmen of the US two tax-writing committees, have kicked off their bipartisan tax reform road-show (The Simpler Taxes For America Tour) in Minnesota,with Baucus conceding that getting the corporate tax rate down to 25% is a bit of a stretch.
For the story, go here. (Registration required)
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Slaughter & Rees Report - The Remarks Chairman Bernanke Dreams of Delivering
by Matthew Slaughter & Matthew Rees (Slaughter & Rees Repoort)
In remarks at his June 19 press conference, U.S. Federal Reserve Chairman Ben Bernanke discussed underwhat conditions the Fed's current policy expansion ofquantitative easing might slow and even end. In the days since, global asset markets have swung dramatically.we imagine that many, perhaps even the Chairman himself, dream of a stronger, more-stable future.
For the report, go here.
In remarks at his June 19 press conference, U.S. Federal Reserve Chairman Ben Bernanke discussed underwhat conditions the Fed's current policy expansion ofquantitative easing might slow and even end. In the days since, global asset markets have swung dramatically.we imagine that many, perhaps even the Chairman himself, dream of a stronger, more-stable future.
For the report, go here.
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Can a Piece of Paper Earn Billions?
by Charles I. Kingson (Tax Analysts, Tax Notes Today)
Charles I. Kingson is an adjunct professor at New York University School of Law.
In this article, Kingson explainswhy transfer pricing enforcement iswanting and suggests that stopping the hemorrhage of income to tax havens could be accomplished by repealing section 1297(d).
For the article, go here. (Subscription required)
Charles I. Kingson is an adjunct professor at New York University School of Law.
In this article, Kingson explainswhy transfer pricing enforcement iswanting and suggests that stopping the hemorrhage of income to tax havens could be accomplished by repealing section 1297(d).
For the article, go here. (Subscription required)
Posted on
Tax reform can aid multinationals, cut deficit
by
Imagine a librarywhere many books have been borrowed and are long overdue. There is a case for an amnesty to get the books back and move on. There is a case for saying that rules are rules and fines must be paid. But theworst strategy is to keep indicating that an amnesty may come soonwithout ever introducing it. And this is roughlywherewe are in our corporate tax debate.
No one is satisfiedwith the U.S. corporate tax system. Some argue the main problem is that,while corporate profits are extraordinarily high relative to gross domestic product, tax collections are relatively low. Many very successful companies pay little or nothing in taxes at a timewhen the budget deficit is a major concern, hundreds of thousands of defenseworkers are being furloughed and lotteries are being held to determinewhich children Head Start can no longer afford to help.
But others say the main problem is that the United States has a higher corporate tax rate than any other major country and, unlike other countries, imposes severe taxes on income earned outside its borders. This, they argue, unfairly burdens companies engaged in international competition and discourages the repatriation of profits earned abroad. The resulting patterns of investment are also said to benefit foreignworkers at the expense of their U.S. counterparts.
For the article, go here.
Imagine a librarywhere many books have been borrowed and are long overdue. There is a case for an amnesty to get the books back and move on. There is a case for saying that rules are rules and fines must be paid. But theworst strategy is to keep indicating that an amnesty may come soonwithout ever introducing it. And this is roughlywherewe are in our corporate tax debate.
No one is satisfiedwith the U.S. corporate tax system. Some argue the main problem is that,while corporate profits are extraordinarily high relative to gross domestic product, tax collections are relatively low. Many very successful companies pay little or nothing in taxes at a timewhen the budget deficit is a major concern, hundreds of thousands of defenseworkers are being furloughed and lotteries are being held to determinewhich children Head Start can no longer afford to help.
But others say the main problem is that the United States has a higher corporate tax rate than any other major country and, unlike other countries, imposes severe taxes on income earned outside its borders. This, they argue, unfairly burdens companies engaged in international competition and discourages the repatriation of profits earned abroad. The resulting patterns of investment are also said to benefit foreignworkers at the expense of their U.S. counterparts.
For the article, go here.
Posted on
European Union: BEPS Project Needs to Consider EU Law Prohibitions, Official Says
by Kevin A. Bell (Bloomberg BNA Daily Tax Report)
As the Organization for Economic Cooperation and Development's base erosion and profit shifting project advances, policy makers should take into account restrictions under European Union law that limit the ability of the 28 EU members to change their domestic tax laws, a European Commission official said July 2.
Philip Kermode, director of the Directorate-General for Taxation and Customs Union, said that although the EU is fully committed to the objectives of the BEPS project, there isthe necessity to avoid solutions, at least for European Union countries, thatwould be actually contrary to our [EU] treaties, and thereforewhich could not possibly applywithin the EU.
For the story, go here. (Subscription required)
As the Organization for Economic Cooperation and Development's base erosion and profit shifting project advances, policy makers should take into account restrictions under European Union law that limit the ability of the 28 EU members to change their domestic tax laws, a European Commission official said July 2.
Philip Kermode, director of the Directorate-General for Taxation and Customs Union, said that although the EU is fully committed to the objectives of the BEPS project, there isthe necessity to avoid solutions, at least for European Union countries, thatwould be actually contrary to our [EU] treaties, and thereforewhich could not possibly applywithin the EU.
For the story, go here. (Subscription required)
Posted on
Subpart F Supply Chain Distribution Structures Outside the Scope of Subpart F
by Lowell D. Yoder (Bloomberg BNA Daily Tax Report)
Income derived by a controlled foreign corporation (CFC) of a U.S. corporation from the purchase and sale of products generally is not subject to U.S. taxation; however, such income is subject to current U.S. taxation underSubpart F if the income fallswithin the definition of foreign base company sales income (FBCSI).
Sales income derived in many foreign supply chain distribution structures is not FBCSI. Generally, the FBCSI rules do not applywhere a CFC purchases property from an unrelated person and sells the property to an unrelated person. For this purpose, purchases from or sales to disregarded entities are not considered as related-party transactions, and paying service fees to related persons for purchasing or selling assistance does not trigger the application of the FBCSI rules.
For the article, go here. (Subscription required)
Income derived by a controlled foreign corporation (CFC) of a U.S. corporation from the purchase and sale of products generally is not subject to U.S. taxation; however, such income is subject to current U.S. taxation underSubpart F if the income fallswithin the definition of foreign base company sales income (FBCSI).
Sales income derived in many foreign supply chain distribution structures is not FBCSI. Generally, the FBCSI rules do not applywhere a CFC purchases property from an unrelated person and sells the property to an unrelated person. For this purpose, purchases from or sales to disregarded entities are not considered as related-party transactions, and paying service fees to related persons for purchasing or selling assistance does not trigger the application of the FBCSI rules.
For the article, go here. (Subscription required)
Posted on
Reflections on PPL and Its Implications for Cash Flow Taxes
by Charles E. McLure, Jr. (Tax Analysts, Tax Notes)
Charles E. McLure Jr. is a senior fellow, emeritus, at the Hoover Institution at Stanford University. As Treasury deputy assistant secretary from 1983 to 1985, he had primary responsibility for developing Treasury's proposals to President Reagan that underlay the Tax Reform Act of 1986. Hewas the principal author of the amicus brief filed by Rosanne Altshuler et al. on behalf of PPL Corp. in its recent case before the Supreme Court. George Zodrow provided useful comments on an earlier version of this article.
On May 20 the Supreme Court held unanimously that thewindfall tax imposed on the excess profits of privatized U.K. companieswas eligible for the foreign tax credit, rejecting the IRS position that creditability should be governed by the form of the tax rather than its economic substance.
For the article, go here. (Subscription required)
Charles E. McLure Jr. is a senior fellow, emeritus, at the Hoover Institution at Stanford University. As Treasury deputy assistant secretary from 1983 to 1985, he had primary responsibility for developing Treasury's proposals to President Reagan that underlay the Tax Reform Act of 1986. Hewas the principal author of the amicus brief filed by Rosanne Altshuler et al. on behalf of PPL Corp. in its recent case before the Supreme Court. George Zodrow provided useful comments on an earlier version of this article.
On May 20 the Supreme Court held unanimously that thewindfall tax imposed on the excess profits of privatized U.K. companieswas eligible for the foreign tax credit, rejecting the IRS position that creditability should be governed by the form of the tax rather than its economic substance.
For the article, go here. (Subscription required)
Posted on
Corporate Taxes Approach to Taxing Foreign Income Remains Elusive as Baucus, Camp Launch Reform Tour
by Marc Heller (Bloomberg/Daily Tax Report)
As the chairmen of the congressional tax-writing committees travel together to tout their effort to revamp the U.S. tax system, one key element of the corporate tax code—how to tax multinational corporations—still has them on roads that do not quite meet.
For the article, go here. (Subscription required)
As the chairmen of the congressional tax-writing committees travel together to tout their effort to revamp the U.S. tax system, one key element of the corporate tax code—how to tax multinational corporations—still has them on roads that do not quite meet.
For the article, go here. (Subscription required)
Posted on
Economic Analysis: Pfizer's Tax Picture Dominated by U.S. Losses, Repatriation
by Marty Sullivan (Tax Analysts, Tax Notes)
Like its drug business, Pfizer's tax situation is a jumble of events and trends that eludes easy interpretation. Look, for example, at its effective tax rate, shown in Figure 1. It is a roller coaster ride of ups and downs that on its own provides little information aboutwhere the company's tax burden has been orwhere it is going. Is Pfizer a high-tax or low-tax company?
For the article, go here. (Subscription required.)
Like its drug business, Pfizer's tax situation is a jumble of events and trends that eludes easy interpretation. Look, for example, at its effective tax rate, shown in Figure 1. It is a roller coaster ride of ups and downs that on its own provides little information aboutwhere the company's tax burden has been orwhere it is going. Is Pfizer a high-tax or low-tax company?
For the article, go here. (Subscription required.)
Posted on
Sainbury's CEO: Tax is a moral issue and business must be proactive
by Matthew Gilleard, ITR
Justin King, Sainsbury's CEO, has said that tax is a moral issue and that companies should be prepared to explain and defend their tax arrangements.
For the story, go here. (Registration required.)
Justin King, Sainsbury's CEO, has said that tax is a moral issue and that companies should be prepared to explain and defend their tax arrangements.
For the story, go here. (Registration required.)
Posted on
Firms Paid 12.6% Tax Rate in 2010 .
A governmentwatchdog agency found that large, profitable U.S. companies on average paid U.S. federal income tax equaling 12.6% of theirworld-wide income in 2010.
But some analysts questioned the findings by the Government Accountability Office, saying they likely understate effective tax rates in someways.
"This is truly an apples-to-oranges comparison," said Peter Merrill,who heads the national economics and statistics group at PricewaterhouseCoopers LLP, and oftenworkswith big firms.
For the story, go here.
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Outbound F Reorganization Triggers Intangible Property Gain
by Robertwillens (Tax Analysts, Tax Notes)
Robertwillens is the president of Robertwillens LLC, New York, and an adjunct professor of finance at Columbia University Graduate School of Business.
A taxpayer's attempt to transfer intangible property to a foreign affiliate in a manner that obviated the need to report deemed royalty income,was rejected by the IRS Office of Chief Counsel. Based primarily on its understanding of the policy objectives underlying section 367(d), the IRS found that deemed royalty income could not be averted.
For the article, go here. (Subscription required)
Robertwillens is the president of Robertwillens LLC, New York, and an adjunct professor of finance at Columbia University Graduate School of Business.
A taxpayer's attempt to transfer intangible property to a foreign affiliate in a manner that obviated the need to report deemed royalty income,was rejected by the IRS Office of Chief Counsel. Based primarily on its understanding of the policy objectives underlying section 367(d), the IRS found that deemed royalty income could not be averted.
For the article, go here. (Subscription required)
Posted on
Corporate Income Tax: Effective Tax Rates Can Differ Significantly from the Statutory Rate
from GAOwebsite
Large,profitable U.S. corporations paid an average effective federal tax rate of just 12.6 percent in 2010, according to a Government Accountability Office report released July 1 by a pair of senior Democratic and Republican senators.
The report indicates the rates being paid by large corporations arewell less than the U.S. statutory corporate rate of up to 35 percent.
For the report, go here.
Large,profitable U.S. corporations paid an average effective federal tax rate of just 12.6 percent in 2010, according to a Government Accountability Office report released July 1 by a pair of senior Democratic and Republican senators.
The report indicates the rates being paid by large corporations arewell less than the U.S. statutory corporate rate of up to 35 percent.
For the report, go here.
Posted on
International Tax News: July 2013
from PwCwebsite
International Tax News is designed to help multinational organizations keep upwith the constant flow of international tax developments worldwide. Among the topics featured in this month's edition are:
**Amendments to Egypt's income tax law
**Corporate tax reform in Switzerland
**China's SAT provides guidance on offshore indirect equity transfers
**Canada's growing TIEA network
For the July issue, go here.
International Tax News is designed to help multinational organizations keep upwith the constant flow of international tax developments worldwide. Among the topics featured in this month's edition are:
**Amendments to Egypt's income tax law
**Corporate tax reform in Switzerland
**China's SAT provides guidance on offshore indirect equity transfers
**Canada's growing TIEA network
For the July issue, go here.
Posted on
PKN Alert/ TCDR Alert: OECD base erosion and profit shifting project - update on transfer pricing issues
by Aamer Rafig (PwC London)
The Organisation for Economic Co-operation and Development (OECD), on February 12, 2013, issued its initial report regarding Base Erosion and Profit-Shifting (BEPS). Since its release, there have been several discussions between the OECDworking group, representatives from different tax authorities and the business. The BEPS report and the subsequent discussion has created speculation as towhere the key area of focus could land.
For the article, go here.
The Organisation for Economic Co-operation and Development (OECD), on February 12, 2013, issued its initial report regarding Base Erosion and Profit-Shifting (BEPS). Since its release, there have been several discussions between the OECDworking group, representatives from different tax authorities and the business. The BEPS report and the subsequent discussion has created speculation as towhere the key area of focus could land.
For the article, go here.
Posted on
News Analysis: The End of International Tax Planning?
by Marie Sapirie (Tax Analysts, Tax Notes Today)
The sky isn't falling for international tax planning, but there are gray clouds on the horizon.
The Lough Erne Declaration that the G-8 leaders issued on June 18 is not a declaration ofwar on tax planning, but it does signal a broad recognition that profit shifting is a problem that countries need to solve legislatively. Recent hearings in the United States and United Kingdom have indicated that cash-strapped governments are starting to comprehendwhat international tax planning is all about and to formulate ideas about how to curtail it. The G-8's position on automatic information exchange also is a key change for international tax practitioners.
At the American Bar Association U.S.-Latin America Tax Planning Strategies conference on June 14, Patricia Brown, director of the University of Miami School of Law's graduate program in taxation, spoke to international lawyers about governments and said that "it looks like they're finally getting it." Until now, changes to tax rules have not really altered the fundamentals of international tax practice because legislators and taxpayers have not been speaking a common language, she said. Because lawmakers don't understand practitioners, "they ask thewrong questions andwrite thewrong rules," Brown said. But that dynamic may be changing.
For the article, go here. (Subscription required)
The sky isn't falling for international tax planning, but there are gray clouds on the horizon.
The Lough Erne Declaration that the G-8 leaders issued on June 18 is not a declaration ofwar on tax planning, but it does signal a broad recognition that profit shifting is a problem that countries need to solve legislatively. Recent hearings in the United States and United Kingdom have indicated that cash-strapped governments are starting to comprehendwhat international tax planning is all about and to formulate ideas about how to curtail it. The G-8's position on automatic information exchange also is a key change for international tax practitioners.
At the American Bar Association U.S.-Latin America Tax Planning Strategies conference on June 14, Patricia Brown, director of the University of Miami School of Law's graduate program in taxation, spoke to international lawyers about governments and said that "it looks like they're finally getting it." Until now, changes to tax rules have not really altered the fundamentals of international tax practice because legislators and taxpayers have not been speaking a common language, she said. Because lawmakers don't understand practitioners, "they ask thewrong questions andwrite thewrong rules," Brown said. But that dynamic may be changing.
For the article, go here. (Subscription required)
Posted on
Hints About the OECD BEPS Action Plan
by Lee A. Sheppard (Tax Analysts, Tax Notes Today)
Officials from members of the OECD and observer countries met in Paris theweek of June 24 to agree to an action plan to implement the OECD base erosion and profit-shifting (BEPS) report (http://www.oecd.org/tax/beps.htm). The action plan is expected to be released around July 15, in time for the meeting of the G-20 finance ministers.
For the story, go here. (Subscription required)
Officials from members of the OECD and observer countries met in Paris theweek of June 24 to agree to an action plan to implement the OECD base erosion and profit-shifting (BEPS) report (http://www.oecd.org/tax/beps.htm). The action plan is expected to be released around July 15, in time for the meeting of the G-20 finance ministers.
For the story, go here. (Subscription required)
Posted on
News Analysis: The Brave New World of the Dependent Agent PE
by Lee A. Sheppard (Tax Analysts, Tax Notes)
In news analysis, Lee A. Sheppard reports on a discussion at a June 14 conference sponsored by the Vienna University of Economics and Business on the dependent agent permanent establishment concept of the model treaty and how it could be modernized.
For the article, go here. (Subscription required.)
In news analysis, Lee A. Sheppard reports on a discussion at a June 14 conference sponsored by the Vienna University of Economics and Business on the dependent agent permanent establishment concept of the model treaty and how it could be modernized.
For the article, go here. (Subscription required.)
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