Int'l Tax News

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American companies and global supply networks: driving US economic growth and jobs by connecting with the world

In an extensive report sponsored by the Business Roundtable, the United States Council for International Business, and the United States Council Foundation,Dartmouth Professor Matthew J. Slaughter explainswhat American companies must do to
succeed in todays dynamic global economy.

For the full text of the prepublication version of Professor Slaughter's report, go here.

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As anger over alleged tax avoidance rises, British MPs vow action on multinationals

The UK Parliament's Public Accounts Committee at a November 12 hearing grilled executives from Google Inc., Amazon.com Inc., and Starbucks Corp. over their transfer pricing policies, suggesting that the companieswere engaged in shifting income out of the U.K. to tax havens.

For coverage of the hearing, go here.

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Tax competition and the trend toward territoriality

In a new two-page paper, University of Michigan Law School Professor Reuven Avi-Yonah examines the key aspects of the recent trend toward territorial taxation, includingthe easewithwhich this tax competition allows multinational corporations to avoid taxation in the countries inwhich their goods are produced, and how the correct reforms to CFC rules, togetherwith enhanced transfer pricing enforcement, can minimize the harm the trend toward tax competition can inflict on the stability of the US corporate tax base.

For the abstract of Avi-Yonah's paper, and to download the full text of the paper, go here.

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Avi-Yonah testifies at hearing on offshore profit-shifting and the US tax code

University of Michigan Law School Professor testified at the September 20, 2012, hearing of the US Senate Finance Committee Permanent Subcommittee on Investigations on "Offshore Profit Shifting and the U.S. Tax Code."

To read Avi-Yonah's testimony and that of the otherwitnesses, go here.

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Avi-Yonah makes case for equalizing tax rates applied to capital and labor

In U. of Michigan Law & Econ Research Paper No. 12-008, University of Michigan Law School Professor Reuven Avi-Yonah responds towhat he sees as a central premise of tax scholarship of the last 30 years -- the greater mobility of capital than labor. Recently, Avi-Yonah notes, scholars such as Edward Kleinbard have recommended that the US adopt a variant of the 'dual income tax' model used by the Scandinavian countries, underwhich income from capital is subject to significantly lower rates than labor income because of its supposedly greater mobility.

Avi-Yonah argues that the premise uponwhich this argument is built is mistaken, because for individual US taxpayers (as opposed to corporations), there are significant limitations on their ability to avoid tax by moving their capital overseas.

For the abstract of this paper, and to download the paper, go here.

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Australian Business Tax Working Group issues final report on possible corporate rate cut

  • By Business Tax Working Group
The Australian Treasury's Business Taxworking Group (BTWG), established in 2011 to exploreways inwhich a corporate tax cut could be funded fromwithin the business tax system, has issued its final report, concluding that itwas "unable to recommend a revenue neutral package to lower the company tax rate."

For the full text of the BTWG Final Report, go here.

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Base erosion and profit shifting (2)

Writing in the June 2012 issue of theworld Commerce Review, Masatsugu Asakawa, the Chair of the OECD Committee on Fiscal Affairs and Japan's Deputy Vice-Minister of Finance for International Affairs, explainswhy recent events in the financial sector indicate that corporate tax policy, and in particular its international side, may need a new look.

Asakawa concludes that "It is more important now than ever that taxpayers pay the
right amount of tax at the right time and in the right place."

For the full text of the article, go here.

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Tax Reforms and Corporate Tax Competition

In an unpublished paper, Professors Rosanne Altshuler of Rutgers University and Timothy Goodspeed of the Hunter College and Graduate Center, CUNY, examine the relationship between tax reforms and corporate tax competition. The authors note that corporate tax competition is an important issuewith broad ramifications for tax policy, yet economists have precious little empirical insight into the tax competition process,which normally manifests itself in large tax reforms.

For the full text of the paper, go here.

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Is U.S. Multinational Dividend Repatriation Policy Influenced by Reporting Incentives?

A study in the September 2012 issue of the American Accounting Association journal The Accounting Review concludes that an accounting technique known as permanently reinvested earnings, or PRE, reduces multinational firms' repatriation of foreign affiliates' earnings (through dividends paid to U.S. parent firms) by roughly 20% a year.while acknowledging that high U.S corporate tax rates and the ability to defer payment play a major role in keeping earnings abroad, it finds that "repatriation is more sensitive to the repatriation tax rate in the presence of reporting incentives," so much so that "firmswith high reporting incentives repatriate, on average, 16.6% to 21.4% less per year than firmswith low reporting incentives."

"Our study suggests that companieswould repatriate about 20% more than they currently do if they didn't have this accounting tool that enables them to put a gloss on their financial statements," comments Leslie A. Robinson, an accounting professor at Dartmouth College,who carried out the studywith Prof. Linda Krull of the University of Oregon and Prof. Jennifer Blouin of the University of Pennsylvania.

For a press release on the article, go here

For the full article, go here

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Treasury official: US tax reform efforts must be informed by international fight against base erosion

Appearing at the recent GW/IRS Insititute on Current Issues in International Taxation, Treasury Deputy Assistant Secretary for International Tax Affairs Manal Corwin said efforts to US international tax rules must take placewithin the context of global efforts to combat base erosion. She said in particular that the OECD project on base erosion and profit shifting (BEPS)would "inform the conversation."

For complete coverage of Corwin's remarks, go here. (Subscription required.)

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Designing an "ironclad" US territorial tax system will be difficult, Shay says

Addressing the National Tax Association on November 16, Harvard Law School professor Stephen Shay --who has extensive international tax experience in both government and private practice --warned attendees that practitionerswill findways to avoid a territorial-based corporate tax.

For coverage of Shay's remarks, go here.

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Why advanced manufacturers need tax reform

In an opinion piece published on politico.com, Intel's Peter Cleveland explains how pro-innovation tax policy "can level the playing field for American businesses, expand our advanced manufacturing base and move forward an innovation-based economy."

To read Cleveland's article, click here.

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Durst suggests changes to OECD guidance on transfer pricing for intangibles

In a Tax Notes viewpoint, international tax practitioner Michael C. Durst,who formerly served as director of the IRS advance pricing agreement program, offers suggestions for improving the OECD's proposed modifications to its transfer pricing guidance regarding the taxation of income from intangible property.

To read Durst's viewpoint, click here.

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UK and German Finance Ministers call for corporate tax coordination

In a joint statement issued at the G-20 finance ministers meeting in Mexico city, the finance ministers of the United Kingdom and Germany called for better coordination of corporate tax regimes because changes in global business practices have exposedweaknesses in the current regimes.

The Daily Tax Report story on the statement may be found here.

The joint statement may be found here.

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US corporate taxes: myths and facts

In a recentwall Street Journal op-ed piece, Business Roundtable President John Engler discusses aspects of the US corporate tax system that influencewhether US corporations choose to operate overseas and if so,whether to repatriate foreign earnings.

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Kleinbard examines tax policy implications of "stateless income"

In a Tax Notes special report, University of Southern California Gould School of Law Professor Edward D. Kleinbard examines the tax consequences and policy implications of the phenomenon of "stateless income" -- income that is 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 but that is subject to tax only in a jurisdiction that is neither the source of the production factors throughwhich itwas derived nor the domicile of the group's parent company.

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Full text of UK revenue official's speech to AEI/ITPF tax reform event is now available

David Gauke of Her Majesty's Treasury delivered the central presentation at the September 27 American Enterprise Institute event -- co-sponsored by the International Tax Policy Forum -- "UK tax reform: a road map for the US?"

The full text of Gauke's presentation is now available.

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Full video of AEI/ITPF event, "UK tax reform: A road map for the US?" is now available!

  • By ITPF
On September 27, the American Enterprise Insitutute,with the International Tax Policy Forum as co-sponsor, hosted an important tax policy event, "UK tax reform: A road map for the US?"

The event featured prominent US and UK international tax policy experts -- from the private sector, academia, and government -- assessing the applicability of the UK reforms to the US situation.

To view the video, please go to: http://www.aei.org/events/2012/09/27/uk-tax-reform-a-road-map-for-the-us/

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Clausing and Hufbauer debate merits of territorial taxation

In a series of Tax Notes articles, Kimberly A. Clausing, a professor of economics at Reed College, and Gary Clyde Hufbauer, the Reginald Jones Senior Fellow at the Peterson Institute for International Economics, debate the possible effects of a U.S. move toward territorial taxation of corporations.

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