Int'l Tax News
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)
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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)
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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.)
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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.)
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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)
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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)
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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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Digital Permanent Establishment (Digital PE): A Road Ahead forE-commerce Taxation
by Sagarwagh (Academia.edu)
With nations all over theworld raising concerns over tax avoidance duewidespread e-commerce transactions, it is essential to analyze the shortcomings in the existing law and find practical solutions to plug the issue of revenue leakage.
Any domestic tax statute gets the teeth to impose tax on the people (taxpayers) by the virtue ofcharging section in the tax statute. The primary requirement to be fulfilled by a contracting state for putting a particular transaction to taxwhether domestic or cross-border is to define the incidence and scope of charging section in its domestic tax law. This means that, the contracting state should provide for express provisions in its domestic tax statue in respect taxation system it has adopted (i.e. Incidence of tax / jurisdiction to tax–territorial orworldwide residence taxation).
In case of cross–border transactions, especially the ones inwhich the income arises in contracting state to resident of other contracting state, the domestic tax laws of the contracting state define the degree up towhich the contracting state seeks to levy charge of tax on resident ofother contracting state. The provisions of this nature can be termed scope provisions.
This research paperwill first analyze the existing legal provisions in relation to e-commerce taxation and need of Digital Permanent Establishment (Digital PE), and then suggest proposedlegal framework both in municipal (domestic) laws of countries and treaties to subject e-commerce transaction to taxation in source jurisdictions through constitution of Digital PE.
For the paper, go here.
With nations all over theworld raising concerns over tax avoidance duewidespread e-commerce transactions, it is essential to analyze the shortcomings in the existing law and find practical solutions to plug the issue of revenue leakage.
Any domestic tax statute gets the teeth to impose tax on the people (taxpayers) by the virtue ofcharging section in the tax statute. The primary requirement to be fulfilled by a contracting state for putting a particular transaction to taxwhether domestic or cross-border is to define the incidence and scope of charging section in its domestic tax law. This means that, the contracting state should provide for express provisions in its domestic tax statue in respect taxation system it has adopted (i.e. Incidence of tax / jurisdiction to tax–territorial orworldwide residence taxation).
In case of cross–border transactions, especially the ones inwhich the income arises in contracting state to resident of other contracting state, the domestic tax laws of the contracting state define the degree up towhich the contracting state seeks to levy charge of tax on resident ofother contracting state. The provisions of this nature can be termed scope provisions.
This research paperwill first analyze the existing legal provisions in relation to e-commerce taxation and need of Digital Permanent Establishment (Digital PE), and then suggest proposedlegal framework both in municipal (domestic) laws of countries and treaties to subject e-commerce transaction to taxation in source jurisdictions through constitution of Digital PE.
For the paper, go here.
Posted on
Cross-Border Taxation: OECD Draft Aims to Clarify Tax Treatment Of Employment-Termination Payments
by Rick Mitchell (Bloomberg, Daily Tax Report)
The Organization for Economic Cooperation and Development June 25 released a discussion draft aimed at clarifying the tax treaty treatment of various cross-border payments made following the termination of employment.
The organization said commentary for the OECD Model Tax Convention on Income and Capital currently has limited guidance on such payments, and deals exclusivelywith the extent towhich they constitutepensions or other similar remuneration.
For the story, go here. (Subscription required)
The Organization for Economic Cooperation and Development June 25 released a discussion draft aimed at clarifying the tax treaty treatment of various cross-border payments made following the termination of employment.
The organization said commentary for the OECD Model Tax Convention on Income and Capital currently has limited guidance on such payments, and deals exclusivelywith the extent towhich they constitutepensions or other similar remuneration.
For the story, go here. (Subscription required)
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Delaney's Delusion -- Latest Proposed Tax Amnesty for Repatriated Offshore Profits Would Create Infrastructure Bank Run by Corporate Tax Dodgers
by Citizens for Tax Justice (website)
Congressman John Delaney, a Democrat from Maryland, has proposed to allow American corporations to bring a limited amount of offshore profits back to the U.S. (torepatriate these profits)without paying the U.S. corporate tax thatwould normally be due. This type of tax amnesty for repatriated offshore profits is euphemistically called arepatriation holiday by its supporters. The Congressional Research Service has found that a similar proposal enacted in 2004 provided no benefit for the economy and that many of the corporations that participated actually reduced employment.
For the report, go here.
Congressman John Delaney, a Democrat from Maryland, has proposed to allow American corporations to bring a limited amount of offshore profits back to the U.S. (torepatriate these profits)without paying the U.S. corporate tax thatwould normally be due. This type of tax amnesty for repatriated offshore profits is euphemistically called arepatriation holiday by its supporters. The Congressional Research Service has found that a similar proposal enacted in 2004 provided no benefit for the economy and that many of the corporations that participated actually reduced employment.
For the report, go here.
Posted on
Country-by-Country Tax Information Should Be Confidential, Treasury Officials Say
by David D. Stewart (Tax Analysts, Tax Notes Today)
With both the G-8 and the OECD's base erosion and profit shifting (BEPS) project examining expanded country-by-country reporting by multinationals, Treasury officials say the tax information should not be made available to the public.
While transparency is an important issue, it must "be set in an appropriate context," Brian Jenn, attorney-adviser in the Treasury Office of International Tax Counsel, said at a June 25 District of Columbia Bar Association Taxation Section international tax luncheon.
For the story, go here. (Subscription required)
With both the G-8 and the OECD's base erosion and profit shifting (BEPS) project examining expanded country-by-country reporting by multinationals, Treasury officials say the tax information should not be made available to the public.
While transparency is an important issue, it must "be set in an appropriate context," Brian Jenn, attorney-adviser in the Treasury Office of International Tax Counsel, said at a June 25 District of Columbia Bar Association Taxation Section international tax luncheon.
For the story, go here. (Subscription required)
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Through a Latte, Darkly: Starbucks' Window into Stateless Income Tax Planning
by Edward D. Kleinbard (Social Science Research Network)
This paper uses Starbucks Corporation, the premier roaster, marketer and retailer of specialty coffee in theworld, as an example of stateless income tax planning in action.Stateless income comprises income derived for tax purposes by a multinational group from business activities in a country other than the domicile of the group's ultimate parent company, butwhich is subject to tax only in a jurisdiction that is neither the source of the factors of production throughwhich the incomewas derived, nor the domicile of the group's parent company.
The paper reviews both Starbucks recent U.K. tax controversy (including a parliamentary inquiry),which revolved around the intersection of its consistent unprofitability in the United Kingdomwith large deductible intragroup payments to Dutch, Swiss and U.S. affiliates, and its more recent submission to the U.S. Houseways and Means Committee. The paper draws from this review two lessons.
First, if Starbucks can organize itself as a successful stateless income generator, any multinational firm can.
Second, The Starbucks story in particular, its U.K. experience demonstrates the fundamental opacity of international tax planning, inwhich neither investors in a public firm nor the tax authorities in any particular jurisdiction have a clear picture ofwhat the firm is up to.
For the paper, go here.
This paper uses Starbucks Corporation, the premier roaster, marketer and retailer of specialty coffee in theworld, as an example of stateless income tax planning in action.Stateless income comprises income derived for tax purposes by a multinational group from business activities in a country other than the domicile of the group's ultimate parent company, butwhich is subject to tax only in a jurisdiction that is neither the source of the factors of production throughwhich the incomewas derived, nor the domicile of the group's parent company.
The paper reviews both Starbucks recent U.K. tax controversy (including a parliamentary inquiry),which revolved around the intersection of its consistent unprofitability in the United Kingdomwith large deductible intragroup payments to Dutch, Swiss and U.S. affiliates, and its more recent submission to the U.S. Houseways and Means Committee. The paper draws from this review two lessons.
First, if Starbucks can organize itself as a successful stateless income generator, any multinational firm can.
Second, The Starbucks story in particular, its U.K. experience demonstrates the fundamental opacity of international tax planning, inwhich neither investors in a public firm nor the tax authorities in any particular jurisdiction have a clear picture ofwhat the firm is up to.
For the paper, go here.
Posted on
Keep It Simple, Stupid: The Key to Tax Reform
by Martin Lobel (Tax Analysts, Tax Notes Today)
Martin Lobel, a partner at Lobel Novins & Lamont LLP and chair of Tax Analysts' board of directors, argues that the United States must strengthen and simplify the tax code to provide a broad tax base before carving out new loopholes to "reform" the code.
The views expressed herein are solely the author's and do not necessarily reflect the views of Tax Analysts.
For the viewpoint, go here. (Subscription required.)
Martin Lobel, a partner at Lobel Novins & Lamont LLP and chair of Tax Analysts' board of directors, argues that the United States must strengthen and simplify the tax code to provide a broad tax base before carving out new loopholes to "reform" the code.
The views expressed herein are solely the author's and do not necessarily reflect the views of Tax Analysts.
For the viewpoint, go here. (Subscription required.)
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A Closer Look at the New Competent Authority Council
by Marie Sapirie (Tax Analysts, Tax Notes Today)
Competent authorities in the 43 OECD Forum on Tax Administration (FTA) member stateswill soon have a new avenue to discuss issues before they encounter them in the context of a mutual agreement procedure (MAP). The new forumwill be an exercise in intergovernmental cooperation that could make the process of resolving MAP disputes more efficient.
The FTA MAP forumwill be organized under the auspices of the FTA. Michael Danilack, deputy commissioner (international), IRS Large Business and International Division, recently emphasized the importance of the FTA as a multilateral body and the plans for increased coordination of tax administration among its members. The forumwill be open to all the members of the FTA,which includes countries that are not OECD members, said Jonathan Leigh Pemberton of the OECD Centre for Tax Policy and Administration.
For the story, go here. (Subscription required.)
Competent authorities in the 43 OECD Forum on Tax Administration (FTA) member stateswill soon have a new avenue to discuss issues before they encounter them in the context of a mutual agreement procedure (MAP). The new forumwill be an exercise in intergovernmental cooperation that could make the process of resolving MAP disputes more efficient.
The FTA MAP forumwill be organized under the auspices of the FTA. Michael Danilack, deputy commissioner (international), IRS Large Business and International Division, recently emphasized the importance of the FTA as a multilateral body and the plans for increased coordination of tax administration among its members. The forumwill be open to all the members of the FTA,which includes countries that are not OECD members, said Jonathan Leigh Pemberton of the OECD Centre for Tax Policy and Administration.
For the story, go here. (Subscription required.)
Posted on
Economic Analysis: New Corporate Coalition Accepts That Reform Won't Be Painless
by Martin A. Sullivan (Tax Analysts, Tax Notes Today)
Therewas a time not long agowhen corporate America hoped it could have it all. Itwould lobby for a corporate rate cut and a territorial system and let somebody elseworry about footing the bill. Andwhy shouldn't business think thatway? After all, President Georgew. Bush pushed through huge individual tax rate cuts in 2001 and capital gains and dividend rate cuts in 2003without paying for them.
But then a series of events transformed the prospect of revenue-losing corporate tax reform from difficult to near impossible. It beganwith the financial crisis that plunged the economy into a deep recession and triggered skyrocketing deficits.
On June 4 a group of 42 U.S. corporations formed the Alliance for Competitive Taxation (ACT). This group has fully embraced the new realistic approach to corporate tax reform. According to itswebsite: "After studying this for over two years, our members understand that to fully pay for a more competitive tax system requires sacrificing specific tax breaks they currently benefit from and tough rules to protect the U.S. tax base."
For the article, go here. (Subscription required)
Therewas a time not long agowhen corporate America hoped it could have it all. Itwould lobby for a corporate rate cut and a territorial system and let somebody elseworry about footing the bill. Andwhy shouldn't business think thatway? After all, President Georgew. Bush pushed through huge individual tax rate cuts in 2001 and capital gains and dividend rate cuts in 2003without paying for them.
But then a series of events transformed the prospect of revenue-losing corporate tax reform from difficult to near impossible. It beganwith the financial crisis that plunged the economy into a deep recession and triggered skyrocketing deficits.
On June 4 a group of 42 U.S. corporations formed the Alliance for Competitive Taxation (ACT). This group has fully embraced the new realistic approach to corporate tax reform. According to itswebsite: "After studying this for over two years, our members understand that to fully pay for a more competitive tax system requires sacrificing specific tax breaks they currently benefit from and tough rules to protect the U.S. tax base."
For the article, go here. (Subscription required)
Posted on
Economic Analysis: The 3-Way Tug of War for Intangible Profits
by Martin A. Sullivan (Tax Analysts, Tax Notes Today)
Let's keep it simple. There are basically three approaches to taxing intangible profits. They can be taxedwhere intangibles are developed,where products are sold, orwhere the costs of intangible development are funded.
Because the three approaches havewidely different implications for the distribution of corporate tax revenue among governments and for theworldwide effective tax rates paid by corporations, international tax reform cannot really proceed until tough choices are made. At the Houseways and Means Committee hearing on June 13, all three approaches received a lot of attention. Unfortunately for thosewho like to be optimistic about the prospects for tax reform, the hearing clarified that sharp differences of opinion remain on the critical issue ofwhere intangible income should be subject to tax.
For the article, go here. (Subscription required.)
Let's keep it simple. There are basically three approaches to taxing intangible profits. They can be taxedwhere intangibles are developed,where products are sold, orwhere the costs of intangible development are funded.
Because the three approaches havewidely different implications for the distribution of corporate tax revenue among governments and for theworldwide effective tax rates paid by corporations, international tax reform cannot really proceed until tough choices are made. At the Houseways and Means Committee hearing on June 13, all three approaches received a lot of attention. Unfortunately for thosewho like to be optimistic about the prospects for tax reform, the hearing clarified that sharp differences of opinion remain on the critical issue ofwhere intangible income should be subject to tax.
For the article, go here. (Subscription required.)
Posted on
News Analysis: Hazards of Debt Push-Downs
By Lee A. Sheppard (Tax Analysts, Tax Notes Today)
What are American multinationals really good at? Tax avoidance --that's obvious. Getting ordinary people to upload personal information for sale to advertisers -- check. Overpaying their top executives -- check.
But there's another dubious skill that they're internationally known for: buying and selling companies. Sometimes they argue against tax measures on the ground that some mythical European competitor might beat them to an acquisition.
On June 20 the International Tax Institute explored the tax obstacles to loading target companieswith acquisition debt towash out their locally taxable income -- a time-honored acquisition technique. Although the United States has interest deduction restrictions that are honored in the breach, European governments are exercised about debt push-down and are adopting measures to restrict interest deductions.
For the article, go here. (Subscription required)
What are American multinationals really good at? Tax avoidance --that's obvious. Getting ordinary people to upload personal information for sale to advertisers -- check. Overpaying their top executives -- check.
But there's another dubious skill that they're internationally known for: buying and selling companies. Sometimes they argue against tax measures on the ground that some mythical European competitor might beat them to an acquisition.
On June 20 the International Tax Institute explored the tax obstacles to loading target companieswith acquisition debt towash out their locally taxable income -- a time-honored acquisition technique. Although the United States has interest deduction restrictions that are honored in the breach, European governments are exercised about debt push-down and are adopting measures to restrict interest deductions.
For the article, go here. (Subscription required)
Posted on
Cadbury: The great tax fudge
By Jonathan Ford, Sally Gainsbury and Vanessa Houlder (Financial Times)
Itwas a deal that provoked visceral reactions in Britain. Even before Kraft completed its contentious £11.5bn purchase of Cadbury three years ago, politicianswerewarning the US group against trying to make afast buck out of the UK confectioner.
Painted as a cost-crunching manufacturer ofplastic cheese, the US conglomeratewas seen as a threat not only to Cadbury's unique British heritage but also to its tax contributions.
Theworst fears of critics appeared to be realised just months after the dealwhen it emerged that the new owner (renamed Mondelez following a 2011 demerger)would reorganise Cadbury inways that ensured it paid little or no tax in Britain.
Kraft planned to shift Cadbury's management and purchasing activities offshore to its European headquarters in low-tax Switzerland, leaving the UK operation as little more than a shell, ladenwith £8bn of debt.
Newspapers claimed that £60m of annual tax paymentswould be lost and politicianswere incensed.The publicwill say that this is just tax avoidance and the publicwill be right, said Lindsay Hoyle, the deputy speaker of the House of Commons.
But the truth is that HM Revenue & Customs had little to lose from the deal. As a Financial Times review of Cadbury's tax affairs has discovered, the chocolate maker paid an average of £6.4m a year in current UK tax on its operations in the decade before the takeover.
For the story, go here.
Itwas a deal that provoked visceral reactions in Britain. Even before Kraft completed its contentious £11.5bn purchase of Cadbury three years ago, politicianswerewarning the US group against trying to make afast buck out of the UK confectioner.
Painted as a cost-crunching manufacturer ofplastic cheese, the US conglomeratewas seen as a threat not only to Cadbury's unique British heritage but also to its tax contributions.
Theworst fears of critics appeared to be realised just months after the dealwhen it emerged that the new owner (renamed Mondelez following a 2011 demerger)would reorganise Cadbury inways that ensured it paid little or no tax in Britain.
Kraft planned to shift Cadbury's management and purchasing activities offshore to its European headquarters in low-tax Switzerland, leaving the UK operation as little more than a shell, ladenwith £8bn of debt.
Newspapers claimed that £60m of annual tax paymentswould be lost and politicianswere incensed.The publicwill say that this is just tax avoidance and the publicwill be right, said Lindsay Hoyle, the deputy speaker of the House of Commons.
But the truth is that HM Revenue & Customs had little to lose from the deal. As a Financial Times review of Cadbury's tax affairs has discovered, the chocolate maker paid an average of £6.4m a year in current UK tax on its operations in the decade before the takeover.
For the story, go here.
Posted on
Pre-takeover Cadburys aggressive tax avoidance exposed
by Sally Gainsbury, Jonathan Ford and Vanessa Houlder (Financial Times)
Cadbury, the British confectionery makerwhich became a cause célèbre for tax justice campaigners after itwas acquired by US food group Kraft in 2010, engaged in aggressive tax avoidance schemes before the takeover thatwere designed to slash its UK tax bill by more than a third.
A Financial Times investigation into the tax affairs of the company established in 1824 by Quakers and famous for its philanthropic ethos has uncovered tax avoidance schemes former senior executives admitwerehighly aggressive.
The reality of Cadbury's tax affairs contrastswith the claim of campaigners and politicians that Kraft's takeoverwould cut its UK tax payments by £60m a year.
In fact, in the decade before the takeover, Cadbury paid an average of £6.4m a year in current tax on its ongoing UK operations, despite annual British profits of £100m and turnover of more than £1bn.
For the story, go here.
Cadbury, the British confectionery makerwhich became a cause célèbre for tax justice campaigners after itwas acquired by US food group Kraft in 2010, engaged in aggressive tax avoidance schemes before the takeover thatwere designed to slash its UK tax bill by more than a third.
A Financial Times investigation into the tax affairs of the company established in 1824 by Quakers and famous for its philanthropic ethos has uncovered tax avoidance schemes former senior executives admitwerehighly aggressive.
The reality of Cadbury's tax affairs contrastswith the claim of campaigners and politicians that Kraft's takeoverwould cut its UK tax payments by £60m a year.
In fact, in the decade before the takeover, Cadbury paid an average of £6.4m a year in current tax on its ongoing UK operations, despite annual British profits of £100m and turnover of more than £1bn.
For the story, go here.
Posted on
G-8 tax call wont be answered quickly on Hill
by Kelsey Snell and Lauren French (Politico)
Lawmakers from both parties are almost universally singing the praises of a new international plan to crack down on global tax evaders but thatwont translate into legislative action any time soon.
Principles unveiled Tuesday at the Group of Eight meeting in Northern Ireland called on tax authorities in theworld's leading economies to automatically share informationwith other countries to fight tax evasion. The agreement also said countries should change rules that allow companies to legally shift profits to low-tax jurisdictions to avoid paying taxes.
The deal essentially amounts to strong suggestions aboutways to make companies more transparent and governments more accountable for their tax policies. The Obama administration already has mechanisms in place to follow through butwill need buy-in from Congress on some proposals.
For the story, go here.
Lawmakers from both parties are almost universally singing the praises of a new international plan to crack down on global tax evaders but thatwont translate into legislative action any time soon.
Principles unveiled Tuesday at the Group of Eight meeting in Northern Ireland called on tax authorities in theworld's leading economies to automatically share informationwith other countries to fight tax evasion. The agreement also said countries should change rules that allow companies to legally shift profits to low-tax jurisdictions to avoid paying taxes.
The deal essentially amounts to strong suggestions aboutways to make companies more transparent and governments more accountable for their tax policies. The Obama administration already has mechanisms in place to follow through butwill need buy-in from Congress on some proposals.
For the story, go here.
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Tax Legislation: Lawmakers Aim to Lighten Taxes On Foreign Investors in Real Estate Trusts
by Marc Heller (Bloomberg)
Federal lawmakers are rekindling an effort to ease taxes on foreignerswho invest in real estate in the United States.
Two dozen senators, led by Sens. Robert Menendez (D-N.J.) and Mike Enzi (R-Wyo.), introduced legislation June 18 to allow more foreign investors in real estate investment trusts to avoid taxation, raising from 5 percent to 10 percent the share of a publicly-held company a foreign investor may ownwithout triggering a tax through the Foreign Investment in Real Property Tax Act (FIRPTA).
For the article, go here. (Subscription required)
Federal lawmakers are rekindling an effort to ease taxes on foreignerswho invest in real estate in the United States.
Two dozen senators, led by Sens. Robert Menendez (D-N.J.) and Mike Enzi (R-Wyo.), introduced legislation June 18 to allow more foreign investors in real estate investment trusts to avoid taxation, raising from 5 percent to 10 percent the share of a publicly-held company a foreign investor may ownwithout triggering a tax through the Foreign Investment in Real Property Tax Act (FIRPTA).
For the article, go here. (Subscription required)
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3M Could Succeed in Legal Challenge of Transfer Pricing Regulation, Practitioner Says
By Kristen A. Parillo (Tax Analysts; Tax Notes Today)
If the Tax Court follows recent Supreme Court case law on regulatory deference, technology company 3M Co. could succeed in its legal challenge of a 1994 Treasury regulation that permits the IRS to make a transfer pricing reallocationwithout regard to foreign legal restrictions, a practitioner said June 14.
For the story, go here. (subscription required.)
If the Tax Court follows recent Supreme Court case law on regulatory deference, technology company 3M Co. could succeed in its legal challenge of a 1994 Treasury regulation that permits the IRS to make a transfer pricing reallocationwithout regard to foreign legal restrictions, a practitioner said June 14.
For the story, go here. (subscription required.)
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G8 seeks rewrite of global tax rules
By George Parker and Vanessa Houlder in Lough Erne (Financial Times)
G8 leaders tried to plug the holes in their public financeswith a sweeping commitment to shake-up international corporate tax rules, including a new crackdown on tax evasion and the shadowy owners of shell companies.
The leaders of eight of theworld's biggest economies signed a 10-point Lough Erne Declaration that calls for tax authorities around theworld to automatically share information. It also urges countries to change the rules that let multinational companies shift profits across borders to avoid taxes and require them to reportwhat tax they paywhere.
For the story, go here.
G8 leaders tried to plug the holes in their public financeswith a sweeping commitment to shake-up international corporate tax rules, including a new crackdown on tax evasion and the shadowy owners of shell companies.
The leaders of eight of theworld's biggest economies signed a 10-point Lough Erne Declaration that calls for tax authorities around theworld to automatically share information. It also urges countries to change the rules that let multinational companies shift profits across borders to avoid taxes and require them to reportwhat tax they paywhere.
For the story, go here.
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Backing for tax and secrecy crackdown
By Vanessa Houlder (Financial Times)
UK Prime Minister David Cameron did not hold back on the superlatives on Tuesday afternoonwhen he declared a historic advance had been made at the Group of Eight summitwith thepotential to rewrite the rules on tax and fight thescourge of tax evasion.
For the story, go here.
UK Prime Minister David Cameron did not hold back on the superlatives on Tuesday afternoonwhen he declared a historic advance had been made at the Group of Eight summitwith thepotential to rewrite the rules on tax and fight thescourge of tax evasion.
For the story, go here.
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G-8 to Fight Tax Evasion -- Proposals Call for Changes in Laws to Stop Companies From Shifting Profits Across Borders
By Ainsley Thomson & John McKinnon (Wall Street Journal)
The Group of Eight leading industrialized nations agreed to proposals to tackle tax avoidance and evasion that call for new laws to stop businesses from shifting profits across borders and urge greater transparency about company ownership.
Tuesday's action reflected growing momentum among the largest economies for joint action to shore up their sometimes-leaky tax systems and shine more light in an often-murky area.
But the agreementswere short on specifics andwill require lengthy and difficult negotiations to implement, both for G-8 members and other countries aswell. Some activists criticized the G-8 for not going further, particularly on multinational businesses that often pay relatively low taxes thanks to porous rules.
For the story, go here.
The Group of Eight leading industrialized nations agreed to proposals to tackle tax avoidance and evasion that call for new laws to stop businesses from shifting profits across borders and urge greater transparency about company ownership.
Tuesday's action reflected growing momentum among the largest economies for joint action to shore up their sometimes-leaky tax systems and shine more light in an often-murky area.
But the agreementswere short on specifics andwill require lengthy and difficult negotiations to implement, both for G-8 members and other countries aswell. Some activists criticized the G-8 for not going further, particularly on multinational businesses that often pay relatively low taxes thanks to porous rules.
For the story, go here.
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Osborne raises hopes of G8 tax deal
By Jim Pickard, Chief Political Correspondent (Financial Times)
George Osborne has raised the hopes of an imminent G8 deal on tax as he declared that there had been rapid progress in talks over a newregister thatwould show the ownership structures of companies.
The British government has said it isleading theway on transparency by creating a central register of company ownership, although it is still unclearwhether thiswill be opened up to the public or just to the tax authorities.
The UK is trying to persuade all the other G8 countries to sign up to the action plan onbeneficial ownership, an attempt to shine a light into the often opaque ownership structures in the businessworld.
For the story, go here.
George Osborne has raised the hopes of an imminent G8 deal on tax as he declared that there had been rapid progress in talks over a newregister thatwould show the ownership structures of companies.
The British government has said it isleading theway on transparency by creating a central register of company ownership, although it is still unclearwhether thiswill be opened up to the public or just to the tax authorities.
The UK is trying to persuade all the other G8 countries to sign up to the action plan onbeneficial ownership, an attempt to shine a light into the often opaque ownership structures in the businessworld.
For the story, go here.
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G8 leaders seek common ground on tax
By Lindsaywhipp and Jim Pickard (Financial Times)
Prime Minister David Cameronwill lead a key discussion on tax evasion and avoidance on Tuesday, as Group of Eight leaders tackle an important but complex issue onwhich progress can be slow moving.
While international leaders agree on the need to tackle evasion and increase transparency, it is more difficult for them to find a single voice over how to change tax rules to counter avoidance. This is partly due to the complicated nature of tax legislation across the globe, but also because G8 countries are essentially competing for tax dollars and inward investment in a post financial-crisisworld of high government debt and slow growth.
The aim is to form action plans to increase transparency and make headway on automatic information exchange, ahead of the Group of 20 meeting in September atwhich members are expected to agree concrete steps to tackle profit shifting by multinationals.
For the story, go here.
Prime Minister David Cameronwill lead a key discussion on tax evasion and avoidance on Tuesday, as Group of Eight leaders tackle an important but complex issue onwhich progress can be slow moving.
While international leaders agree on the need to tackle evasion and increase transparency, it is more difficult for them to find a single voice over how to change tax rules to counter avoidance. This is partly due to the complicated nature of tax legislation across the globe, but also because G8 countries are essentially competing for tax dollars and inward investment in a post financial-crisisworld of high government debt and slow growth.
The aim is to form action plans to increase transparency and make headway on automatic information exchange, ahead of the Group of 20 meeting in September atwhich members are expected to agree concrete steps to tackle profit shifting by multinationals.
For the story, go here.
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Havens crackdown: Momentum builds for tax transparency
By Vanessa Houlder (Financial Times)
The 2013 summit has the potential to go down in history asthe turning point in the battle against tax evasion and avoidance, according to David Cameron, UK prime minister.
He has called on governments tobreak down thewalls of corporate secrecy by introducing central registers for corporate ownership. Talkswill also focus on the cross-border sharing of tax information andwhether companies should be encouraged to reportwhat they pay in the countries inwhich they operate on a voluntary basis.
For the story, go here.
The 2013 summit has the potential to go down in history asthe turning point in the battle against tax evasion and avoidance, according to David Cameron, UK prime minister.
He has called on governments tobreak down thewalls of corporate secrecy by introducing central registers for corporate ownership. Talkswill also focus on the cross-border sharing of tax information andwhether companies should be encouraged to reportwhat they pay in the countries inwhich they operate on a voluntary basis.
For the story, go here.
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Foray into global tax fraught with challenges
By James Politi inwashington (Financial Times)
US business groups have been opposed to even the smallest foray into the kind of country-by-country tax reporting debated by Group of Eight leaders, highlighting the challenges in implementing such provisions even·if¬∑agreement¬∑is reached in Northern Ireland.
A key plank of the G8 agenda to boost tax transparency by multinationals has been to force them to at least disclose how much tax they pay in each country.
The EU and the US have taken steps in that directionwith regard to oil, gas and mining companies, but applying these requirements to all sectors is expected to be resisted across the corporateworld.
In the US, the provision requiring country-by-country reporting in the energy sector, buried inside the Dodd-Frankwall Street reform bill enacted three years ago, has been the subject of a legal challenge and lobbying to kill it before it takes effect next year.
For the story, go here.
US business groups have been opposed to even the smallest foray into the kind of country-by-country tax reporting debated by Group of Eight leaders, highlighting the challenges in implementing such provisions even·if¬∑agreement¬∑is reached in Northern Ireland.
A key plank of the G8 agenda to boost tax transparency by multinationals has been to force them to at least disclose how much tax they pay in each country.
The EU and the US have taken steps in that directionwith regard to oil, gas and mining companies, but applying these requirements to all sectors is expected to be resisted across the corporateworld.
In the US, the provision requiring country-by-country reporting in the energy sector, buried inside the Dodd-Frankwall Street reform bill enacted three years ago, has been the subject of a legal challenge and lobbying to kill it before it takes effect next year.
For the story, go here.
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UK under pressure from Berlin over tax competition
By Vanessa Houlder and Quentin Peel (Financial Times)
Britain is coming under pressure from Berlin to rein back on tax competition, amid fears that a break on the levy aimed at high tech companieswill undermine German revenues.
Concerns about Britain's efforts to attract investment by cutting taxes have risen as German companies moved to take advantage of an incentive for patent income.
For the story, go here.
Britain is coming under pressure from Berlin to rein back on tax competition, amid fears that a break on the levy aimed at high tech companieswill undermine German revenues.
Concerns about Britain's efforts to attract investment by cutting taxes have risen as German companies moved to take advantage of an incentive for patent income.
For the story, go here.
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UK to set up central tax register
By George Parker, Jim Pickard and Vanessa Houlder (Financial Times)
Britain is to lead by example in its push for greater tax transparency by setting up a new central register to try to ensure that the true owners of shell companies often located in tax havens pay their taxes.
David Cameron hopes to persuade other big economies to set up similar registerswhen he chairs the G8 summit in Northern Ireland nextweek, a move designed to recover the billions of pounds in lost revenue suffered by exchequers around theworld.
For the story, go here.
Britain is to lead by example in its push for greater tax transparency by setting up a new central register to try to ensure that the true owners of shell companies often located in tax havens pay their taxes.
David Cameron hopes to persuade other big economies to set up similar registerswhen he chairs the G8 summit in Northern Ireland nextweek, a move designed to recover the billions of pounds in lost revenue suffered by exchequers around theworld.
For the story, go here.
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Cameron under pressure to push for G8 tax transparency deal
By Vanessa Houlder and George Parker in London (Financial Times)
David Cameron is under pressure to build on a tax transparency dealwith British offshore territories by pushing for aglobal agreement at the summit of the Group of Eight leading economies .
Global poverty charitieswelcomed the UK prime ministers success in bringing British territories such as Bermuda into the framework on Saturday but said he needed to go further in promoting real transparency to crack down on tax evasion and aggressive avoidance.
Mr Cameron said the UKwas leading theway on transparency by creating a central register of company ownership. But he faced criticism from campaigners for only offering to consult onwhether it be opened up to the public rather than just tax authorities.
For the story, go here.
David Cameron is under pressure to build on a tax transparency dealwith British offshore territories by pushing for aglobal agreement at the summit of the Group of Eight leading economies .
Global poverty charitieswelcomed the UK prime ministers success in bringing British territories such as Bermuda into the framework on Saturday but said he needed to go further in promoting real transparency to crack down on tax evasion and aggressive avoidance.
Mr Cameron said the UKwas leading theway on transparency by creating a central register of company ownership. But he faced criticism from campaigners for only offering to consult onwhether it be opened up to the public rather than just tax authorities.
For the story, go here.
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Camp Signals Support for 15% Foreign Patent Income Rate: Taxes
by Aaron E. Lorenzo (Bloomberg)
For companieswith a lot of foreign income from intangible products like patents, Dave Camp has a carrot-and-stick approach to overhauling the tax code.
Camp, the top Republican taxwriter in the U.S. House of Representatives, says putting a rate of 15 percent on all foreign income from intellectual property rights and intangibleswould limit revenue erosionwhen Congress pursues broad tax reform, Bloomberg BNA reported.
For the story, go here.
For companieswith a lot of foreign income from intangible products like patents, Dave Camp has a carrot-and-stick approach to overhauling the tax code.
Camp, the top Republican taxwriter in the U.S. House of Representatives, says putting a rate of 15 percent on all foreign income from intellectual property rights and intangibleswould limit revenue erosionwhen Congress pursues broad tax reform, Bloomberg BNA reported.
For the story, go here.
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Editorial: The world needs global tax reform -- G8 leaders must continue their work beyond the summit
As leaders of the Group of Eight leading economies gather in Northern Ireland, David Cameron'swelcome initiative to reform global corporate tax rules may still fall short of definitive success. All the more reason for governments to push on after the summit, together and at home.
For the editorial, go here.
For the editorial, go here.
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Why we need to simplify our corporate tax system
by Eric Schmidt (Financial Times)
The G8 is the forum to decide on the complex issue of company fiscal reform, says Eric Schmidt
As the leaders of theworlds largest economies descend on beautiful, blustery Lough Erne, their briefingswill doubtless be packedwith different ideas for international tax reform. Todays rules are fiendishly complicated and everyonewould benefit from a simpler, more transparent system. That iswhywe have been encouraging a broader debate at the level of the Group of Eight leading economies and the Organisation for Economic Co-operation and Development.
For the commentary, go here.
The G8 is the forum to decide on the complex issue of company fiscal reform, says Eric Schmidt
As the leaders of theworlds largest economies descend on beautiful, blustery Lough Erne, their briefingswill doubtless be packedwith different ideas for international tax reform. Todays rules are fiendishly complicated and everyonewould benefit from a simpler, more transparent system. That iswhywe have been encouraging a broader debate at the level of the Group of Eight leading economies and the Organisation for Economic Co-operation and Development.
For the commentary, go here.
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The G8 agenda: The transparency summit -- Britain's leader envisages a world of tax compliance and clear corporate ownership
At first blush, David Cameron seems an unlikely foe of tax dodgers and their accomplices. Conservatives are traditionally friendly to thewealthy and to big business,who gain most from fancy financial footwork. The City of London enjoys symbiosiswith a cluster of offshore dependenciesincluding Jersey and the British Virgin Islands (BVI)which have a reputation for, at best, inviting tax avoidance and, atworst, aiding financial crime.
But as chair of the summit of the G8 (the biggest industrialised countries) being held in Northern Ireland nextweek, the prime ministerwill push for global reform of theworld economys most shadowy corners. Hewants to improve tax compliance through the cross-border exchange of information, to improve those data by making companies, trusts and the like show their true owners, and to change outdated ruleswhich multinationals exploit to cut their tax bills. His assault is both on the offshore tax havens and on the often dodgier, if lesswell-known, practices in onshore jurisdictions such as Delawareor London.
For the story, go here.
But as chair of the summit of the G8 (the biggest industrialised countries) being held in Northern Ireland nextweek, the prime ministerwill push for global reform of theworld economys most shadowy corners. Hewants to improve tax compliance through the cross-border exchange of information, to improve those data by making companies, trusts and the like show their true owners, and to change outdated ruleswhich multinationals exploit to cut their tax bills. His assault is both on the offshore tax havens and on the often dodgier, if lesswell-known, practices in onshore jurisdictions such as Delawareor London.
For the story, go here.
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WNTS Insight: House Ways and Means Committee tax reform hearing focuses on tax havens, base erosion, and profit shifting
The Houseways and Means Committee today held a hearing on tax reform issues related to US international tax rules and tax havens, base erosion, and profit shifting. The hearing also discussed approaches for reforming US domestic tax rules through rate reduction and base broadening. In addition, the hearing examined OECD initiatives that seek to address concerns over transfer pricing, the tax treatment of intangible property, and related issues as part of an action plan addressing base erosion and profit shifting (BEPS).
For thewNTS Insight, go here.
For thewNTS Insight, go here.
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U.K. Lawmakers Slam Google Over Contrived Tax Strategy
U.K. lawmakers attacked Google Inc. (GOOG) for defending ahighly contrived strategy of booking advertising sales through Ireland to reduce its tax liability in Britain.
Parliament's Public Accounts Committee said in a report published in London today thatpublic confidence in the companywill only be restoredwhen it establishes a corporate structure that ensures Google pays taxwhere it generates profit.
For the article, go here.
Parliament's Public Accounts Committee said in a report published in London today thatpublic confidence in the companywill only be restoredwhen it establishes a corporate structure that ensures Google pays taxwhere it generates profit.
For the article, go here.
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Commentary: "How America Lost Its Way"
Not everyone is an entrepreneur. Still, everyone should try -- if only once -- to start a business. After all, it is small and medium enterprises that are the key to job creation. There is also something uniquely educational about sitting at the deskwhere the buck stops, in a dreary office you've just rented,working day and nightwith a handful of employees just to break even.
As an academic, I'm just an amateur capitalist. Still, over the past 15 years I've started small ventures in both the U.S. and the U.K. In the process I've learned something surprising: It's much easier to do in the U.K. There seemed to be much more regulation in the U.S., not least the headache of sorting out health insurance for my few employees. And therewere certainly more billable hours from lawyers.
For the article, go here.
As an academic, I'm just an amateur capitalist. Still, over the past 15 years I've started small ventures in both the U.S. and the U.K. In the process I've learned something surprising: It's much easier to do in the U.K. There seemed to be much more regulation in the U.S., not least the headache of sorting out health insurance for my few employees. And therewere certainly more billable hours from lawyers.
For the article, go here.
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ACT Statement on Todays Ways and Means Hearing on Tax Reform
The Alliance for Competitive Taxation (ACT), a coalition of 42 leading American businesses that employ millions of Americanworkers, issued the following statement regarding today's Houseways and Means Committee hearing on tax reform:
“ACTwelcomes the hearing today on an important issue to advancing tax reform. ACT supports comprehensive tax reform that lowers the corporate tax rate to 25%, gets rid of corporate tax breaks and preferences and establishes a modern hybrid international tax system. ..."
For the statement, go here.
“ACTwelcomes the hearing today on an important issue to advancing tax reform. ACT supports comprehensive tax reform that lowers the corporate tax rate to 25%, gets rid of corporate tax breaks and preferences and establishes a modern hybrid international tax system. ..."
For the statement, go here.
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Schwartz: Bipartisan Tax Reform Urgently Needed to Keep Jobs in U.S.
U.S. Representative Allyson Y. Schwartz (PA-13) issued the following statement at today's Houseways and Means Committee hearing examining the various tax planning strategies used by multinational corporations to shift income out of the United States and into low-tax jurisdictions.
“Today's hearing highlights the necessity of reforming our tax code. Recent reports have shown that our current tax code puts American businesses, our economy, andworkers at a disadvantage in the global marketplace and robs the federal government of the revenue needed to meet our obligations. Our current tax code makes it easy to game the system and rewards shipping jobs overseas,while giving companies no incentives to create middle-class jobs here at home, said Congresswoman Schwartz.
For the statement, go here.
“Today's hearing highlights the necessity of reforming our tax code. Recent reports have shown that our current tax code puts American businesses, our economy, andworkers at a disadvantage in the global marketplace and robs the federal government of the revenue needed to meet our obligations. Our current tax code makes it easy to game the system and rewards shipping jobs overseas,while giving companies no incentives to create middle-class jobs here at home, said Congresswoman Schwartz.
For the statement, go here.
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Ways and Means Considers Base Erosion and Profit Shifting
Questioning a panel of experts on the merits of a territorial regime, offshore cash stockpiles, and the promotion of American manufacturing, the Houseways and Means Committee considered how best to combat base erosion and profit shifting (BEPS) at a hearing on June 13. Also up for deliberationwas an anti-base-erosion proposal that committee Chair Dave Camp, R-Mich., included in his 2011 discussion drafton corporate taxation.
For the story, go here. (Subscription required.)
For the story, go here. (Subscription required.)
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Transfer Pricing No Call for Formulary Apportionment In OECD Base Erosion Action Plan, Official Says
The Organization for Economic Cooperation and Developmentwill not recommend a shift from the arm's length principle to formulary apportionment in its July action plan on its project addressing base erosion and profit shifting (BEPS), OECD's top tax official told BNA June 13.
For the story, go here. (Subscription required.)
For the story, go here. (Subscription required.)
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Tax Reform: Camp Signals Support for Taxing Foreign Income From Intangibles at 15 Percent Rate
All foreign income attributable to intangible products, such as intellectual property rights, could be taxed at a 15 percent rate as part of a plan to reform the tax code and limit erosion of the U.S. tax base, Houseways and Means Committee Chairman Dave Camp (R-Mich.) said in a plan highlighted June 13.
Companies could get below a 15 percent effective rate by subtracting any credits for foreign taxes paid on the same income, Camp said during a tax reform hearing on tax havens, base erosion, and profit-shifting.
For the story, go here. (Subscription required.)
Companies could get below a 15 percent effective rate by subtracting any credits for foreign taxes paid on the same income, Camp said during a tax reform hearing on tax havens, base erosion, and profit-shifting.
For the story, go here. (Subscription required.)
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Witness Statements at 6/13 W&M Hearing on "Tax Reform: Tax Havens, Base Erosion and Profit-Shifting"
The Houseways and Means Committee has released thewritten testimony of thewitnesses at its June 13 hearing on Tax Reform: Tax Havens, Base Erosion and Profit-Shifting. Thewitnesses are:
- Pascal Saint-Amans, Director, Centre for Tax Policy and Administration, Organisation for Economic Co-operation and Development (OECD);
- Edward Kleinbard, Professor of Law, University of Southern California Gould School of Law; and
- Paul Oosterhuis, Partner, Skadden Arps Slate Meager & Flom LLP.
For the testimony, go here.
- Pascal Saint-Amans, Director, Centre for Tax Policy and Administration, Organisation for Economic Co-operation and Development (OECD);
- Edward Kleinbard, Professor of Law, University of Southern California Gould School of Law; and
- Paul Oosterhuis, Partner, Skadden Arps Slate Meager & Flom LLP.
For the testimony, go here.
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