Int'l Tax News
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News Analysis: Mining for a Solution to Blocked Income at the Tax Court
3M Co.'s challenge to regulations under section 482 holds the promise of a major development in the evolution of the rules on blocked income. Although the fundamental controversy has been around for several years, 3M's case is the first to address the 1994 revision to the regulations. Over 40 years, the government has lost three cases, including one at the Supreme Court, on related issues.
The controversy in 3M Co. v. Commissioner, No. 005816-13 (T.C. 2013), involves a Brazilian restriction on the payment of royalties from 3M Brazil to 3M. The IRS asserts that those restrictions cannot be taken into account because the requirements of reg. section 1.482-1(h)(2)were not met.
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Tax directors seeking "success under pressure" according to EY's 32nd Annual International Tax Conference survey
A new survey announced at EY's 32nd Annual International Tax Conference today brings to life the conference theme "Success under pressure" and explores
the combination of external pressures and internal corporate plans for growth that international
tax and finance executives are managing.
For the release, go here.
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September 2013 Survey of Current Business
Multinational companiesÔøΩboth U.S. and foreignÔøΩare major performers of industrial research and development (R&D) in the United States. For U.S. multinational companies, U.S. parent companies play a dominant role in U.S. R&D activity, accounting for about three-quarters of the domestic R&D performed by all U.S. businesses. Through their U.S. affiliates, foreign multinational companies also play a major role: majority-owned U.S. affiliates account for about 15 percent of U.S. industrial R&D, triple their share of production or employment by all U.S. businesses.
For the report, go here.
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Think Globally, Tax Locally: How Global Tax Laws Could Impact Multinationals
The European Union reached a major milestone in the second quarter of 2013when it officially emerged from its year-and-a-half recession. According to Eurostat, the European Union's statistics office, the 17 countries that use the euro saw economic output grow by 0.3% in Q2 compared to the previous quarter.
Now that the EU's economic output has started to grow, (hopefully) multinational businesseswill get some economic relief. Companies that have been seeing earnings from their European operations decline for the past several months are starting to turn the corner,with growth thatwill drive profitably in these regions again.we're crossing our fingers that the trend continues … but it may not be time to celebrate just yet.
For the story, go here.
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Multinationals beach tax bills in Spanish shells
A rented office overlooking a dusty rail track near Madrid's airportwas until recently theworkplace ofwhatwould appear to be the most productiveworker in all of Spain.
From here a single employee presided over a company that from 2009 to 2011 made ÔøΩ9.9bn of net profits, allwhile earning an annual salary of only ÔøΩ55,000.
The personwasworking for ExxonMobil Spain SL, a holding company for theworld's largest oil group by value,which for several years used a relatively unknown part of Spanish tax law to transfer billions of euros from foreign subsidiaries to the US, helping to significantly reduce its tax bill.
For the story, go here.
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The New Going Dutch
Review & Outlook (Wall Street Journal)
The $29 billion merger that America's Applied Materials AMAT +2.21% and Japan'sTokyo Electron 8035.TO -0.73% announced on Tuesday is a rare trans-Pacific marriage inwhich a U.S. firm seems to be the dominant player. As eye-catching, the companies say that their merged entitywill be incorporated not in Japan or in North AmericaÔøΩbut in the tax-friendly Netherlands.
Among OECD countries, the U.S. ranks at the bottomwith a combined statutory federal and state corporate income tax rate of 39.1%, and Japan is next on the dishonor roll at 37%. America is also, er, exceptional for taxing overseas profits,which dissuades companies from bringing back and reinvesting this capital at home.
For the story, go here.
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BMC Software Appeals Tax Court's Decision on Dividends Received Deduction
BMC Software Inc. is appealing a decision by the U.S. Tax Court that the IRS properly reduced a section 965 dividends received deduction the company receivedwhen it repatriated $721 million from outside the U.S. during its 2006 tax year.
For the story, go here. (Subscription required)
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BEPS: A new approach for taxing multinationals is needed
Mirna Screpante, invited tax researcher at the Max Planck Institute for Tax Law and Public Finance, exploreswhether a new approach for taxing multinationals is needed in light of recent studies into base erosion and profit shifting (BEPS).
For the story, go here.
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ABA Meeting: U.S. Remains Opposed to Separate PE Rules for Digital Economy
The United States continues to oppose creating permanent establishment rules for the digital economy thatwould differ from the general PE rules, Treasury officials said September 20.
"There is no clear reasonwhywe need to have separate rules for PEs in a digital economy that are different from the rules in the regular economy," Douglas Poms, attorney-adviser in the Treasury Office of International Tax Counsel, said at the U.S. Activities of Foreigners and Tax Treaties session of the American Bar Association Section of Taxation meeting in San Francisco. "We are really pushing that question,whywe need special rules for digital."
For the story, go here. (Subscription required)
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ABA Meeting: IRS Is Concerned About Sandwich Structure Unwinds Using Spins
Transactions used by multinationals to unwind so-called sandwich structures -- inwhich either a foreign entity is sandwiched between two U.S. entities or the otherway around, and the entity at the bottom of the structure is spun off to the parent -- raise policy concerns if the entity to be spun had been recently acquired, an IRS official said September 21.
"There are policy concerns presented in a number of different fact patterns," Daniel McCall, special counsel, IRS Office of Associate Chief Counsel (International), said at the Corporate Tax session of the American Bar Association Section of Taxation meeting in San Francisco. "There are concerns in the cross-border areawhen foreign distributing or U.S. distributing distributes a recently purchased company."
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Permanent Establishments: U.S. Officials Blast Virtual PE' Concept, Saying VAT Might Capture Online Sales
Practitioners and Treasury Department officials challenged the French government's proposal for a virtual permanent establishment—based on the idea that Internet sales alone might create a taxable presence for a foreign corporation.
“The U.S. opposes proposals to address the digital economy by adopting territoriality principles such as a virtual permanent establishment, said Brett York, attorney-adviserwith the Office of International Tax Counsel at Treasury, during a panel discussion Sept. 20 at the American Bar Association Sections of Taxation and Real Property Fall CLE Meeting in San Francisco.
For the story, go here. (Subscription required)
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Transfer Pricing: Bay Area Practitioners Say Focus on U.S. Outbound Intangibles' Transfers Is Misguided
A group of San Francisco tax practitioners—allwith firms in tech-heavy sectors—expressed significant skepticism about legislation aimed at curbing tax evasion being considered on Capitol Hill.
Speaking at a panel Sept. 19 at the annual American Bar Association Sections of Taxation and Real Property Fall CLE Meeting in San Francisco, several practitioners questioned some of the basic premises of the current discussion on tax evasion—including the idea that the primary issue today is valuable intellectual property being transferred outside the U.S.
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Profit Shifting: EU Policies Cost Developing Nations Billions in Tax Losses, Claim NGOs
The European Union is failing to complywith its treaty obligations to developing nations as EU and multinational corporations continue to evade billions of dollars in taxes each year, said a group of nongovernmental organizations.
A report by CONCORD, an association of European NGOs, analyzed how some EU policies negatively affect developing countries in the areas of financing for development, food security, natural resources and climate change. The analysis found that developing countries lost up to $569 billion in 2010 due to profit shifting by transnational corporations, amounting to a loss of at least $100 billion a year in tax revenue.
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For the report, go here.
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Transfer Pricing: Treasury Officials: BEPS Should Focus On Stateless Income, Not Reallocating Income
The U.S. government thinks discussions about base erosion and profit shifting (BEPS) should focus narrowly on double nontaxation, orstateless income, rather than looking at allocation issues that could lead to a fight between source and residence countries, two Treasury officials said.
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Economic Analysis: Can the United States Compete Without a VAT?
A new paper from economists at the OECD is filledwith facts and figures about the evolution of theworld's tax systems since the onset of the financial crisis. Five years after the failure of Lehman Brothers, most countries' tax-to-GDP levels are recovering from the initial shock.
In 2011 (the latest year comprehensive data are available) average revenueswere only 1.2 percentage points of GDP below 2007 levels. Average projections for 2014 exceed pre-crisis levels (Pierre LeBlanc, Stephen Matthews, and Kirsti Mellbye, "The Tax Policy Landscape Five Years After the Crisis," OECD Taxationworking Paper No. 17, Sept. 4, 2013).
For the article, go here. (Subscription required,)
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ABA Meeting: Tech Company Tax Directors Defend International Tax Structures
The international structures used by high technology companies based in Silicon Valley and the surrounding area to reduce their effective tax rates are not improper, a panel of corporate tax directors said September 19.
"I don't think any of us feelwe're doing anything that's immoral," said Alan Sankin of Dolby Laboratories Inc. at a Transfer Pricing session of the American Bar Association Section of Taxation meeting in San Francisco. Dolby's decisions are based on the tax laws, and it and other companieswould respond if the rules changed, Sankin said. "At the moment, these are the laws and it'swithin our judgment and the best interests of our shareholders to use those," he said.
For the story, go here. (Subscription required)
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Business Community Questioning BEPS Project Motives, Former Treasury Counsel Says
Several issues surrounding the OECD's base erosion and profit-shifting project remain unclear and have raised concerns among the business community, according to David Ernick of PricewaterhouseCoopers LLP, former Treasury associate international tax counsel and U.S. delegate to OECDworking Party 6.
Speaking on his own behalf September 19 in New York at the Global Transfer Pricing Forum sponsored by the International Tax Review, Ernick said several people asked himwhy the OECD is undertaking the BEPS initiative andwhat it expects the project to achieve. The myriad subjective, undefined terms used throughout the action plan are a chief concern, he said.
For the story, go here. (Subscription required)
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Hodge denounces corporate tax reform
A senior MP has attacked the government's reform of international corporate tax rules for creating a loophole that allows companies to pay less tax in the UK.
Margaret Hodge, chair of the cross-party Public Accounts Committee, said the new rules, designed to stop the artificial diversion of profits to tax havens, contained anabsurd loophole thatwould encourage companies to minimise their UK tax liability.
For the story, go here.
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Government accused of double standards over tax avoidance
After months of championing the global crackdown on tax avoidance by multinationals, the UK government is facing mounting scrutiny at home and abroad over its own aggressive approach to tax competitiveness.
Thisweek, Margaret Hodge, the Labour MPwho has campaigned against corporate tax avoidance, attacked aloophole in reforms thatwould allow companies to cut their UK tax bills by hundreds of millions of pounds.
For the story, go here.
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Special Report: How a German tech giant trims its U.S. tax bill
In July 2012, then-U.S. Treasury Secretary Tim Geithner traveled to an island off the German coast to meetwolfgang Schaeuble, Germany's finance minister. Schaeublewas on vacation, but Geithner visited to discuss the euro zone crisis. Talk also turned to a long-running bugbear of Schaeuble's: corporate tax avoidance.
For the story, go here.
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Practitioners Concerned About Possible Disregard of Arm's-Length Standard for BEPS
A proposal under the OECD project on base erosion and profit shifting that may depart from the arm's-length standard for the transfer pricing of intangibles has practitioners concerned that the standard may be undermined to solve a problem that has not been proven to exist.
Speaking at a September 18 session of the Practising Law Institute's International Tax Issues 2013 program in Chicago, Thomas M. Zollo of KPMG LLP said the case for BEPS has been made through the questioning of executives from successful companies that have achieved low effective tax rates. However, "a full view of the playing field"would show that numerous companies have entered into cost-sharing arrangements that have notworked out aswell, he said.
For the story, go here. (Subscription required)
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CTJ: "FedEx Responds to CTJ, Avoids the Tough Questions about Its Taxes"
As Senator Max Baucus and Congressman Dave Camp, the chairmen of the tax committees in the Senate and House, took their tax reform road show to the FedEx headquarters in Memphis lastweek, CTJ released a short report and op-ed concluding that the company had paid just 4.2 percent of its profits over the previous five years in federal corporate income taxes. FedEx's Corporate Vice President for Tax, Michael D. Fryt, respondedwith an op-ed of his own that took issuewith CTJ but avoided the actual issue raised.
For the report, go here.
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Tax Policy Bulletin: Momentum behind the Action Plan on Base Erosion and Profit Shifting
Leaders of the G20 countries publicly endorsed outline proposals to address BEPS during their summit in St. Petersburg on 4/5 September 2013. Responding to a report presented to them by Angel Gurria, OECD Secretary-General,which included progress on the challenges originally set by them, the G20 encouraged swift time frames for further development and implementation.
For the Bulletin, go here.
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OECD Official Addresses Concerns Surrounding BEPS
The OECD's base erosion and profit shifting (BEPS) project is designed to maintain the ability to eliminate double taxation and ensure that tax is properly attributed to jurisdictionswhere value is created, according to Pascal Saint-Amans, head of the OECD Centre for Tax Policy and Administration.
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Inversion Projects' Progress, or Lack Thereof
The anti-inversion statute, section 7874, doesn'twork verywell at its stated goals, and Congress hasn't bothered to fix section 163(j), the ineffectual interest-stripping rule. And there's not awhole lot the IRS can do about it, except treat the departed corporations the sameway it treats real foreign parents.
Thatwas the implicit message of the September 18 International Tax Institute Inc. lunch in New York,wherewillard Taylor, now an adjunct professor at New York University School of Law, hosted John Merrick, special counsel to the IRS associate chief counsel (international), and Lew Steinberg of Credit Suisse Group AG.
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BEPS Seen as Area of Both Consensus and Conflict
Although the United States still faces significant challenges enacting tax reform, the issue of base erosion and profit shifting is a rare case inwhich there is consensus among U.S. and foreign tax authorities, according to Eric Solomon of Ernst & Young LLP, a panelist at the Practising Law Institute's International Tax Issues 2013 program in Chicago.
"Issues about base erosion are here to stay," Solomon said during a September 18 session on international tax reform. Hewas joined on the panel by Robert Stack, Treasury deputy assistant secretary (international tax affairs),who said the United States faces challenges in its engagement on BEPS.
For the article, go here. (Subscription required)
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Profit Shifting: Base Erosion, Profit Shifting Concerns Driving Tax Overhaul Agenda, Official Says
Multinational corporations need to prepare for a paradigm shift in theway they honor their tax obligations around the globe, despite the political and technical obstacles emerging as nations draft multilateral accords permitting them to limit base erosion and profit shifting (BEPS), a U.S. Treasury Department official said.
Robert Stack, deputy assistant secretary for international tax affairs in Treasury's Office of Tax Policy, pointed to a long list of complexities thatwill confront the Organization for Economic Cooperation and Development's BEPS action plan. Stack said that countries have different motivations and vested interests to protect, potentially hampering progress. Closer to home, Stack pointed to disagreements over BEPS's potential role in congressional negotiations aimed at overhauling the tax code.
For the article, go here. (Subscription required)
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Why the European Councils challenge does not mean the end of the road for the FTT
After lastweek's legal opinion from the European Council stated that part of the residence principle of the proposed European financial transaction tax (FTT) is incompatiblewith European law, some proponents feared theworst. But the end is not necessarily nigh.
For the article, go here.
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A Territorial Tax System Would Create Jobs and Raise Wages for U.S. Workers
Sinceways and Means released its draft legislation on international reform almost two years ago there has been a steady drumbeat of criticism that has for the most part gone unchallenged. This paper pushes back on those criticisms and makes three crucial points.
For the paper, go here.
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The Faltering Financial Transaction Tax and the Future of Wall Street
The financial meltdown in 2008was supposed to change how banks andwall Streetwere regulated and taxed. The idea that tradingwas too volatile and that bankswere engaged in numerous risky transactions caught hold. Therewas a growing belief that financial institutions and investment firms should help fund the cost of future bailouts. However, five years later little has changed. The United States got the Dodd-Frank Act, a heavilywatered-down regulation package, and some of the European Union pushed aheadwith a financial transaction tax. But Treasury and the SEC are struggling to implement the former, and the latter has run afoul of the complicated European legal framework.
For the blog post, go here.
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European Union: European Commission Insists FTT Discussions Continue Despite Council's Legal Concerns
European Taxation Commissioner Algirdas Semeta insisted that negotiations to finalize the terms of the European Union financial transactions tax should continue even though the Council of Ministers legal service concluded that a key principle that defineswhowill be required to pay the levy violates EU single market rules.
Speaking Sept. 14 at the conclusion of a meeting of EU finance ministers in Vilnius, Lithuania, Semeta also insisted thatworkwithin the EU to complete the revision of the EU cross-border savings tax directive should not be delayed towait for the completion of a global standard on information exchange for bank accounts as agreed aweek earlier by the Group of 20 nations in Russia.
For the story, go here. (Subscription required)
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Profit Shifting: OECD's BEPS Project Must Remain Focused on Stateless Income, Stack Says
The Organization for Economic Cooperation and Development's base erosion and profit shifting project must remain focused on addressing the problem of stateless income if the project is to have a chance of success, a U.S. Treasury official said Sept. 13.
Robert Stack, deputy assistant secretary for international tax affairs, said if the BEPS project veers from this objective and seeks instead to rebalance source and residence taxation rights, the project likelywill fail.
For the story, go here. (Subscription required)
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Tax Credits: Foreign Corporate Joint Ventures: Foreign Tax Credit Planning
U.S. multinationals commonly enter into foreign joint ventureswith foreign companies; one important tax consideration is the application of the foreign tax credit ruleswith respect to income derived from the joint venture.
When the foreign joint venture is a corporation, planning into status as a controlled foreign corporation (CFC) can be beneficial.
For the article, go here. (Subscription required)
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BEPS and the Law of Unintended Consequences
This article discusses possible economic implications and ramifications of recent positions on transfer pricing taken by the OECD in its project on base erosion and profit shifting.
For the article, go here. (Subscription required)
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Japan to Consider Corporate Tax Cut in Stimulus Package
Japan is considering a reduction in corporate taxes as part of a planned package to cushion the economy from raising the national sales levy, Economy Minister Akira Amari said.
Paring income taxes is another option,while a lower priority, Amari told reporters in Tokyo. Prime Minister Shinzo Abe earlier this month instructed officials to compile a plan by the end of September to counter the blow from a scheduled 3 percentage point bump in the consumption tax in April, to 8 percent.
For the story, go here.
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Dutch tax avoidance crackdown sparks debate
A Dutch initiative to crack down on tax avoidance by multinational corporations is being fiercely resisted by the business community,with the American Chamber of Commerce in the Netherlandswarning it could drive US corporations to move their European headquarters out of the country.
The Netherlands, Ireland and Luxembourg are facing a European Commission inquiry over tax practices that critics say allow multinationals to lower their tax bills by billions of euros. This month the Netherlands responded to rising criticismwith a plan to tighten conditions for so-called letterbox companies, shell companies that multinationals establish largely for tax purposes.
For the story, go here.
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Adobe shows its creativity with Ireland tax base
Adobe Systems is a pioneer in creativity. Since the 1980s its software has facilitated a desktop publishing revolution.what is lesswell-known is that its creativity extends to its tax structure,which enables the US software company to avoid paying tens of millions of dollars in corporate taxes every year.
By establishing two companies registered in low-tax Ireland, Adobe slashed its tax bill on $2.1bn profits earned outside the US over the three years to the end of December 2012 to $144m, giving it an effective tax rate of 6.9 per cent. During this period the company paid $527.1m in US federal taxes on $1bn in profits an effective tax rate of 52 per cent.
Adobe is one of hundreds of technology and pharmaceutical companies, including Apple, Google and Abbott Laboratories,which funnel non-US sales through Ireland to cut their tax bills. Controversy over these tax avoidance strategies has prompted the Organisation for Economic Co-operation and Development (OECD) to call for an overhaul of global tax rules.
For the story, go here.
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European Union: European Commission, Council Clash On Legal Basis for Financial Transactions Tax
On Sept. 11, the Brussels-based European Commission rebutted a leaked opinion from the legal services of the Council of Ministers,which found a crucial part of the FTT to be incompatiblewith the European Union Treaty.
“We strongly disagreewith the Council legal service's opinion on the FTT.we expect the member states to not just follow the Council legal service's views unquestioningly, but to assess them critically against the Commission's robust legal analysis of this proposal, Emer Traynor, the commission's spokeswoman, said in a statement.
For the article, go here. (Subscription required)
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OECD Transfer Pricing Documentation Draft Shows Naivete, Practitioner Says
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OECD - The Tax Policy Landscape Five Years after the Crisis
The height of the economic and financial crisis is nowwell past, but its aftermath remainswide-ranging,with many OECD countries still someway from restoring strong and sustainable economic growth. Even before the Great Recession OECD economies faced a range of challenges, most notably from globalisation, but also other challenges such as climates change, growing inequality and population ageing. Against this background, this paper discusses how tax policies have responded to fiscal and macroeconomic developments over the past five years and these longer-term structural economic developments.
For the paper, go here.
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Europe financial transaction tax hits legal wall
Europe's plan for an expansive financial transaction tax hit awall after the top legal adviser to finance ministers concluded it exceeds national jurisdiction,infringes on EU treaties andis discriminatory to non-participating states.
The unusually blunt paper from the EU Council legal service, obtained by the Financial Times, deals a heavy blow to a European Commission proposal to introduce a $35bn eurozone levywith global reach.
For the article, go here.
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Looking into sweetheart tax deals
Ireland, the Netherlands and Luxembourg have long been suspected ofwooing multinationals through tax deals. But Brussels preliminary inquiry intowhether some of the tax deals are in contravention of EU state aid rules, adds political pressure at a critical juncture for the countries already under pressure from international efforts to tackle tax avoidance.
The European Commission's move to issue questions to the three member states about their tax relationshipwith individual companies, including Apple and Starbucks, follows recent publication of an action plan by the Paris-based Organisation for Economic Co-operation and Development,which is designed to close corporate tax loopholes that have enabled companies to save tens of billions of euro in tax over the past decade.
For the article, go here.
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Brussels probes multinationals tax deals
Brussels is probing Ireland, Luxembourg and the Netherlands over their tax dealswith multinationals paving theway potentially for a formal investigation into illegal sweeteners.
Europes top competition authority has asked the governments to explain their system of tax rulings and give details of assurances given to several specific companies including Apple and Starbucks according to peoplewho have seen the request.
For the article, go here.
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Congressman Delaney's 'Rebuttal' on His Proposed Tax Amnesty for Offshore Corporate Profits Continues to Misinform
In July, a letter signed by 30 national organizations and a report from Citizens for
Tax Justice (CTJ) bothwarned members of Congress about a proposal from
Congressman John Delaney of Maryland thatwould have the effect of rewarding
corporations that use offshore tax havens to avoid U.S. taxes. Rep. Delaneys staff
respondedwith a rebuttal that is itself based on misinformation about corporate tax law and about the likely effects of the proposal,whichwould provide a tax amnesty for offshore profits (often euphemistically called a repatriation holiday) for corporations that agree to finance an infrastructure bank.
For the report, go here. For the release, go here.
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Washington D.C. talk on corporate and international tax reform
Yesterday I Acela'd from New York towashington D.C. and back again, so that I could spend most of myworking day at a conference, held on Capital Hill in the Rayburn House Office Building,entitled The Federal Income Tax at 100: How Didwe Get Here andwhere Shouldwe Go Next? A Forum of Tax Policy Experts and Tax Policy Makers.
My mission at the conferencewas to give a 15-minute talk on corporate and international tax reform. In the intro for our panel (which discussed reform optionswithin the existing federal income tax generally), the moderator expressed the hope thatwewould point theway forward, assuming that more dramatic reform options (discussed by the preceding panel)were unavailable. But my talk focused instead onwhy it is so hard to specify the bestway forward on corporate and international tax reform, even in the absence of political obstacles.
For the blog post, go here.
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G20 communiqué drives BEPS action forward but implementation will be anightmare
G20 leaders met in St. Petersburg lastweek,with international taxation once again high on the agenda.
For the story, go here.
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Vodafones 3.8% Taxes on $130 Billion Payday Fuels U.K. Dispute
Vodafone Group Plc (VOD)'s $130 billion payout from exiting its Verizonwireless venture is largely passing the tax man by.
U.K. politicians have grilled Google Inc. and Amazon.com Inc. executives on their taxes, and Starbucks Corp. (SBUX) agreed in December to pay a voluntary tax to head off a boycott threat. Vodafone, based in Newbury, England, structured the deal through its holding company in the Netherlands,where it benefited from an exemption rule leaving itwith no taxes due there, either.
The lack of British tax ispretty concerning, Margaret Hodge, chairwoman of the House of Commons Public Accounts Committee, said today on BBC radio as she asked tax officials to review the transaction. Vodafonehas a duty not to aggressively avoid tax, but to pay its fair due to British taxpayers out of the substantialwindfall it is making.
for the story, go here.
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Latin American Tax Newsalert: 2014 Mexican Tax Reform proposals eliminate tax consolidation and flat tax, limit maquiladora regime and introduce a new 10% dividend tax
Yesterday, the Executive Branch of the Mexican government presented its 2014 Tax Reform package to Congress. The package's most significant proposalswould eliminate the tax consolidation regime, eliminate the Flat Tax (IETU), provide a more limited maquiladora regime, retain the 30% income tax ratewithout reduction, introduce a new corporate-level tax on dividends, limit the deduction of certain related party payments, and eliminate the statutory audit (dictamen fiscal) requirement.
For the PwC Newsalert, go here.
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In Memphis, Baucus, Camp Call for Fairer, Simpler Tax Code that Makes U.S. More Competitive
Senate Finance Committee Chairman Max Baucus (D-Mont.) and Houseways and Means Committee Chairman Dave Camp (R-Mich.) met todaywith family farmers and local business leaders in Memphis, Tennessee, to talk about the critical need to overhaul the nation's tax code in order to boost its fairness, reduce complexity and improve the economy.
“Plain and simple, the tax code is broken. Fixing it is the bestway to spark long-term growth in our economy, create good-paying jobs, and make families lives easier, Baucus and Camp said in a joint statement.Whether it's a chat over coffee in a family's kitchen or a meetingwith business leaders and their employees,were hearing the same thing: the American peoplewant a new tax code that's fair and simple. That'swhat tax reform is about.
For the release, go here.
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Mexican President Announces Tax Overhaul --- Pena Nieto Offers Social-Security System, Unemployment Insurance in Exchange for Higher Levies to Boost Nonoil Revenue
President Enrique Pena Nieto, facing protests over his attempts to revamp Mexico's economy, unveiled a long-awaited tax overhaul on Sunday, promising to create a universal social-security system and unemployment insurance in exchange for a series of tax increases that seek to boost the government's nonoil revenue.
The proposal, expected towin congressional approval, seeks to raise rates on top earners to 32% from 30%, introduces a 10% capital-gains tax, and closes some corporate loopholes. It also seeks to slap a special tax on sugary soft drinks, in a countrywhere obesity and diabetes are rising.
For the article, go here.
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