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Int'l Tax News

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5 Considerations When Repatriating Cash For COVID-19

  • By Natalie Olivio

Natalie Olivio

U.S. companies seeking access to their offshore earnings during the coronavirus pandemic may not be able to grab the cash easily due to the inherent complexity of the repatriation process,whichwas nuanced even before the current economic uncertainty.

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Practical Transfer Pricing in Uncertain Economic Conditions

  • By Robin Hart

In this article, the author discusses how to reevaluate transfer prices based on market conditions caused by COVID-19 and mitigate complexities associatedwith year-end processes. He also examines how (re)structuring intercompany transactionswith high upfront payments can be effective in deploying cashwithin a multinational group.

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The Impact of the COVID-19 Pandemic on Tax Residence Rules

  • By Michael J.A. Karlin

In this article, the author examines the definition of a resident alien undersection 7701(b)in the context of the coronavirus pandemic.

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Navigating New Foreign Income Tax Allocation and Apportionment Regs

  • By Carrie Brandon Elliot

Carrie Elliot reviews new proposed regs that allocate taxes to income categories in order to calculate the foreign tax credit limitation.

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Tax Optimism for a Post-Pandemic World

  • By Mindy Herzfeld

Mindy Herzfeld questionswhether the economic crisis caused by the coronavirus pandemic could lead to beneficial changes for the international tax system.

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Global Tax Reform Project Should Consider COVID-19, ICC Says

  • By Stephanie Soong Johnston

TheOECDshould take into account the coronaviruspandemic's effects on businesses as it continuestowork on updating the global corporate tax rules for the digital age, a major trade group said.

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Business Groups Urge OECD, EU to Address Tax Relief Roadblocks

  • By Annagabriella Colon

Twelve business groups have asked theOECDand theEuropean Commissionto remove obstacles towithholding tax relief on cross-border portfolio investments that have arisen as a result of the COVID-19 pandemic.

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Firms Ask EU for Delay of Cross-Border Tax Arrangement Reporting

  • By Sarah Paez

Financial associations are asking theEuropean Commissionto extend the deadline for implementation of requirements for intermediaries to report cross-border tax arrangements that promote avoidance until 2021 because of complications from thecoronavirus.

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IRS Relaxes Tax Residency Requirements Amid COVID-19 Pandemic

  • By Kiarra M. Strocko

A nonresidentwho is temporarily present in the United States for up to 60 consecutive calendar days because of COVID-19 travel disruptionswill not be considered a U.S. resident under theIRS's substantial presence test.

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Companies must align local and global tax functions for CbCR audits

  • By Josh White

Country-by-country reporting (CbCR) has pushed Indian taxpayers to seek out greater alignment between the local tax function and the global tax team.

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Denmark Nixes COVID-19 Relief for Companies in Tax Havens

  • By Annagabriella Colon

Denmark and Poland are among the first countries to exclude companies located in tax havens from claiming coronavirus relief, and two advocacy groups arepushing the United Kingdom to follow suit.

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The Transformation of International Tax

  • By Ruth Mason

The recession of 2008 precipitated a political crisis that motivated an unprecedented international project to curb corporate tax dodging. This Article argues, contrary to dominant scholarly views, that this effort transformed international tax ÔøΩ changing its participants, agenda and institutions, norms, and even its legal forms. Perhaps most important, efforts to close corporate tax loopholes opened a rift over the resulting revenues that threatens a hundred-year-old tax treaty framework. This Article identifies and critically evaluates these changes from the perspectives of revenue, inclusivity, legitimacy and accountability, innovation, and durability.

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Addressing Challenges in the Hard-to-Value Intangibles Guideline

  • By Andrew Hughes

In this article, the author uses a Monte Carlo simulation approach to valuing hard-to-value intangibles, discusses the use of publicly available data in considering all known possibilities in performing a simulation, andwalks practitioners through the challenges of implementing that kind of model.

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COVID-19 Shifts Companies' Attention to Tariff Exception

  • By Annagabriella Colon

With the shift to e-commerce gaining momentum because of social distancing requirements, some U.S. companies are starting to focus on aworkaround that can eliminate some customs duties, including section 301 tariffs.

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Dutch Advisory Committee Urges More Limited Deductions for MNEs

  • By Kiarra M. Strocko

The Dutch government should lower limits on tax deductions for businesseswith profitable activities in the Netherlands and ensure that the country is at the forefront of international tax reform, an advisory committee recommended.

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Swedish Court Rejects Use of Antiabuse Rule for Intragroup Debt

  • By Ryan Finley

The option to capitalize interest payments under a loan agreement between a parent company and its subsidiary does not create a separate debt relationship subject to antiavoidance rules, according to Sweden'sSupreme Administrative Court.

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G-20 Global Tax Revamp More Relevant Than Ever, Minister Says

  • By Stephanie Soong Johnston

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G-20 Global Tax Revamp More Relevant Than Ever, Minister Says (1)

  • By Stephanie Soong Johnston

TheG-20continues to push forward on anOECD-led solution to modernize the global tax system, since countries hit hard by COVID-19will soon need to think about economic recovery, a top Saudi minister said.

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A New Era of Risk-Based IRS Transfer Pricing Enforcement


In this report, the authors trace the development of theIRS Large Business and International Division's new approach to transfer pricing enforcement, and they explain the practical implications for taxpayers and advisers.

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Overtaken by Events: Should the OECD Delay BEPS 2.0?

  • By Robert Goulder

The OECD inclusive framework is in the midst of something historic, assuming it can finish the job. The ensemble of 137 jurisdictions is trying to revise the international consensus,which for the past century has determined how corporate profits are divvied up among governmentswith rival tax claims. That's no small task. Thework is being done at the behest of the G-20 nations, and it's the type of globally coordinated mega-project that comes around only once in a generation.

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The Impact of the COVID-19 Pandemic on Tax Residence Rules (1)

  • By Michael J.A. Karlin

In this article, the author examines the definition of a resident alien undersection 7701(b)in the context of the coronavirus pandemic.

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World Must Not Lose Focus on Global Tax Overhaul, Germany Urges

  • By Stephanie Soong Johnston

Theworld needs to stand together, not only to fight the coronavirus pandemic, but also to agree on an OECD solution to update global tax rules for the digital age, Germany's finance minister said.

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NOL Break May Require Reconsideration of Transition Tax Position

  • By Andrew Velarde

U.S. taxpayers looking to take advantage of net operating loss relief under the coronavirus stimulus bill may find themselves facing the difficult task of reconsidering previously taken return positions related to complicated transition tax calculations.

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Companies Save Billions in Taxes by Shifting Assets Around Globe

  • By Richard Rubin

Multinational corporations are devising new strategies to keep their taxes low, saving billions of dollars by navigating around attempts by the U.S. and European countries to tighten the tax net.

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OECD Helps Countries Interpret Tax Treaties During Crisis 

  • By Isabel Gottlieb

In guidance released Friday, the Organization for Economic Cooperation and Development explained how countries can interpret treaties in instanceswhere employees are stranded abroad orworking remotely due to the crisis.

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Tax Law Changes May Limit Benefits of New Loss Carryback Perk 

  • By Siri Bulusu

Multinational companies should think carefully about how carrying back losses to more profitable yearswill impact their international tax strategy.

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Antitrust and the Corporate Tax: A Missed Opportunity? 

  • By Reuven S. Avi-Yonah

Professor Avi-Yonah discusses an alternative method of antitrust enforcement, the corporate tax. He succinctly argues three points before concluding that anew Digital Services Tax (DST) may play a useful regulatory role to curb the monopoly power of Big Tech. First, even a low corporate tax rate requires corporations to provide difficult to obtain information to the government. Second, because a sufficiently high tax can be destructive corporate management may limit its aggressiveness in fear of such a high tax. Lastly, the corporate tax rate can be raised or lowered in response to specific desirable or undesirable activity.

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Taxes in the Time of Coronavirus: Is it Time to Revive the Excess Profits Tax? 

  • By Reuven S. Avi-Yonah

Professor Avi-Yonah argues that given that most corporations are losing money, but some are now earning enormous profits due to the crisis, it is time to revive thewartime excess profits taxes that the US deployed inworldwar I andworldwar II to prevent corporatewinners from achieving this form of opportunistic unjust enrichment.
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Insight: Transfer Pricing in a PandemicLessons From China 

  • By Glenn DeSouza

Using cases and solutions based on the latest Chinese legal, accounting, and economic developments, the author discusseswhether the recent pandemic should be used to invoke force majeure clauses in transfer pricing policies.

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Take Action Now, U.K. Tells Tech Companies in Tax Guidance

  • By Hamza Ali

Complyingwith the U.K. digital services tax could bring legal and technical headaches in a time of crisis, tax practitionerswarn because Parliament has not yet been able to give its final approval.

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OECD Offers Tax Authorities a Guide to Coronavirus Measures

  • By Isabel Gottlieb

Global tax authorities are extending filing deadlines,waiving penalties for late payments, and issuing refunds more quickly to help companieswalloped by the coronavirus pandemic, a recently released OECD report says.

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India to Levy New Tax on Foreign E-Commerce Cos From April 1 

  • By Shruti Srivastava

Indiawill start levying a new tax on foreign e-commerce operators beginning April 1, according to a recently passed law.All non-resident e-commerce platform operatorswill have to pay the new tax -- equalization levy -- at the rate of 2% of the income received.
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Uber Case in U.K. Could Become Model for How to Tax Gig Economy 

  • By Meg Bernhard

A U.K. tax case could alter how Uber Technologies Inc. does business across Europe and put pressure on the country's tax authority to retroactively collect up to 1.5 billion pounds in value-added taxes.
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Insight: Does It Make Sense to Impose Higher Taxes on Automated Digital Services?

  • By Jeff VanderWolk¬†

The authorquestionswhether it makes sense for the OECD to be pursue increased taxes on automated digital services businesses in the near futurewhen those serviceswill be key to a global economic recovery.
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Constructive Dialogue: BEPS and the TCJA

  • By Reuven S. Avi-Yonah

Professor Reuven S. Avi-Yonah arguesthatwhile the US is typically seen as influencing international tax law, in the case of the TCJA, the US legislationwas heavily influenced by the OECD BEPS project, and that the continuing OECDwork in Pillars I and II is likely to have a similar influence on the future development of US international tax law.
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Insight: Covid-19 Puts Limited Risk Structure at RiskAnalysis from the Chinese Angle 


In light of thepressure on the Chinese economy and businesses brought about by the outbreak of Covid-19, the authors examinethe Chinese limited risk manufacturing, distribution, and service companies,which are common in the supply chains of many multinational corporations, to see how these companies can address their transfer pricing arrangements in light of changed circumstances.

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Tax Law Changes Make Life Harder for Firms Facing Coronavirus Losses

  • By Richard Rubin

The 2017 tax law is making life harder for U.S. businesses that suffer sudden losses, and Congress is under pressure to relax some of those provisions as the economy reels from the impact of the coronavirus.
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Companies Owing Repatriation Tax May Miss Payment Extension

  • By Siri Bulusu

Companies should plan to pay tax on assets brought back from overseas on the normal schedule this year, despite Treasury's having extended the tax payment deadline for companies and individuals.

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U.K. Relaxes Tax Rules for Nonresidents Fighting COVID-19

  • By Stephanie Soong Johnston

HM Treasuryhas proposed changing the rules to allow skilled nonresidents to come to the United Kingdom to helpwith its COVID-19 responsewithout affecting their tax residency status.

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Examining the Proposal to Abolish Dividend Distribution Tax in India

  • By Srishti Singh

In this article, the author discusses the impact of the proposed abolishment of India's dividend distribution tax,with a particular focus on how the change may affect the overall investment climate.

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Using Arbitration to Resolve Transfer Pricing Disputes and the Impact of the OECD's Unified Approach Proposal

  • By Gabriel Capristano Cardoso

In this article, the author considers the use of alternative forms of dispute resolution to resolve tax treaty disputes, focusing on the potential benefits of and obstacles to using mandatory binding arbitration to resolve transfer pricing disputes, including those that may arise under theOECD's unified approach for allocating profits in the digital economy.

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Final Hybrid Mismatch Regs Deviate Little From Earlier Rules

  • By Andrew Velarde

New guidance on hybrid mismatches may include small measures of relief for taxpayers, but practitioners hoping for bigger changes from earlier guidance may be disappointed, if not surprised.

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Digital Services Taxes: How Did We Get Into This Mess?

  • By Peter A. Barnes and H. David Rosenbloom

In this article, the authors consider the state of digital services taxation following theOECD's initiative to develop global digital tax rules.

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Switzerland Must Fix Beneficial Ownership Shortfalls, OECD Says

  • By Stephanie Soong Johnston

While Switzerland has improved its exchange of information mechanisms, including adding more staff to handle data requests, it must do more to improve its beneficial ownership data availability, theOECD's transparency body said.

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Irish Tax Authorities Relax Residency Requirements

  • By Kiarra M. Strocko

TheIrish Revenue Commissionersare calling the COVID-19 pandemic a case offorce majeure, saying that a taxpayerwill not suffer negative tax repercussions for being present in Ireland because of travel restrictions.

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Finnish Court Rejects Recharacterization of Intragroup Debt

  • By Ryan Finley

The Finnish tax administration cannot recharacterize an intragroup lender as a service provider because taxpayers' transactions must be respected as structured unless theywere undertaken for avoidance, according to Finland'shighest courtin tax disputes.

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Close Encounters With Public CbC Reporting

  • By Robert Goulder

Robert Goulder examines how public country-by-country reporting almost made it into Congress's pandemic relief legislation.

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USTR Lists Digital Services Tax Among Trade Sore Spots in 2020

  • By Annagabriella Colon

TheOffice of the U.S. Trade Representative(USTR) said itwill continue towork toward the elimination of unilateral digital services taxes,which it says are key roadblocks to international digital trade.

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Countries Relax Tax Residency Rules for Cross-Border Workers

  • By Kiarra M. Strocko

The COVID-19 pandemic has raised tax residency concerns for individuals and businesseswith employeeswho have been forced to remain in foreign countries and could face unforeseen tax obligations because of government-mandated lockdowns.

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Takeaways From EU Commissioner of the Economys First Tax Policy Speech

  • By Rick Minor

In this article, the author considers the EU tax policy agenda outline laid out in the first tax policy speech ofPaolo Gentiloni, the new EU commissioner of the economy.

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