Int'l Tax News

The president provided further details about his expected tariff moves.

Asian countries are among the most vulnerable to President Trump’s economic grievances. But they are also best placed to make deals to minimize their exposure.

Donald Trump is considering tariffs on countries that levy digital services taxes against American companies and tightening rules on Chinese investment in the US as he widens the scope of his global trade war.

President Donald Trump and his economic team are increasingly focusing on the revenues his tariffs would generate as he seeks to get tax cuts through Congress, pointing to an ominous path ahead for countries trying to avoid a trade war.

Adam Kern examines President Trump’s executive memorandum on the global tax deal, arguing that it will have a limited effect on the stability of pillar 2 because the United States maintains the global intangible low-taxed income structure and the strategic dynamics that support pillar 2 thus remain largely intact.

Ryan Finley explains why the IRS’s new approach to periodic adjustments will likely bring the United States into greater conflict with its treaty partners.

The OECD is soliciting feedback from the business community on an additional set of “validation rules” that will accompany the global minimum tax return.

The EU Council’s Polish presidency will ask member states whether to include international tax developments in their draft conclusions on a “future-proof tax policy which contributes to the competitiveness of the EU.”

Robert Goulder comments on the recent tariff-skipping decision in Harley-Davidson v. Commission.

Michael J. Graetz argues that the United States must reassert its primary taxing rights over income long conceded to other countries, especially income from intellectual property created in the United States, and he explains some changes necessary to make that happen.

The European Commission released a Q&A document regarding the United States' reciprocal tariff policy, including guidance on VAT in relation to tariffs; the EU's trade surplus rules; average tariff rates on both EU and U.S. imports; and asymmetrical tariff structures.

Business groups are calling on Canada to cut or reform taxes to ease the potential economic hit stemming from the Trump administration’s tariff threats.

Hungary’s finance minister proposed that the EU investigate whether the minimum tax can preserve or strengthen the competitiveness of the bloc following the US’ rejection of the global tax deal.

Martin A. Sullivan examines available data to provide insight on the economic effects of potential tariffs on U.S. imports, and he categorizes the strategies companies have considered for mitigating the burden of tariffs.

Mindy Herzfeld examines the potential impact of President Trump’s recently announced tariffs and offers alternatives that could be less disruptive to the U.S. economy.

Countries worldwide appear optimistic about participating in negotiations for a U.N. framework convention on international tax cooperation, despite the United States’ swift exit from the talks in early February.

Lucas de Lima Carvalho explains his proposal for a single virtual jurisdiction in the development of the taxation of artificial intelligence.

The European Commission has issued a statement regarding the announced U.S. tariff policy, saying it would have negative economic effects and promising that "the EU will react firmly and immediately against unjustified barriers to free and fair trade."

Business at OECD issued a letter responding to the Platform for Collaboration on Tax's (PCT) public consultation on its guidance for tax incentives principles for international policy purposes and introducing the OECD's global minimum tax standard, urging the PCT to lighten restrictions regarding tax incentive definitions and jurisdictional autonomy as well as provide explicitly clear pillar 2 guidance.

The future of Canada’s digital services tax and proposed undertaxed profits/payments rule—and possibly its approach to Pillar Two and international tax more broadly—is precarious in the face of international trade pressures and the Trump administration’s threats about the OECD’s global tax deal.

The European Union remains committed to implementing the global tax deal despite the US backtracking, the EU’s top economic official said Tuesday.

President Donald Trump doesn’t like other countries’ value-added taxes. Trump said Thursday that his administration would look at imposing “reciprocal” tariffs against other nations. They would be aimed at offsetting not only the tariffs those countries charge on US goods, but also other regulatory and tax measures that Trump regards as unfair to the US—including VATs, which many countries impose on the sale of goods and services.

Donald Trump has unveiled an overhaul of the US’s trading relationship with many of its partners and allies, launching what he dubs a “fair and reciprocal plan” for trade.

President Trump has ordered advisers to craft new tariffs for countries that have a trade deficit with the United States by calculating all costs related to trade barriers and subsidies provided to domestic corporations.

Reuven S. Avi-Yonah explains why concerns about the risks associated with publicly disclosing country-by-country reports are exaggerated and that the benefits outweigh the costs.

President Donald Trump ordered his administration to consider imposing reciprocal tariffs on numerous trading partners, raising the prospect of a wider campaign against a global system he complains is tilted against the US.

Donald Trump repeatedly attacked the EU over tariffs, taxes, regulations and a legal system that he said was unfair to US companies.

The European Commission has announced the withdrawal of its proposal to revise the interest and royalty directive, which was made partially obsolete by pillar 2, and is now looking at aligning EU antiabuse clauses.

How is it in America’s national interest to let other countries decide what duties we pay?

A state-of-play on the president’s tariffs so far and what might be in store.

 The president said his advisers would devise new tariff levels reflecting countries’ tariffs, taxes, subsidies and other policies affecting trade with the United States.

Ryan Finley explains why the IRS’s recent advice memorandum on periodic adjustments may signal a significant change in transfer pricing enforcement approach.

EU lawmakers have denounced the weaponization of economic policy by the new U.S. administration, and the European Commission has promised a firm response to President Trump’s announced tariffs on EU steel.

Robert Goulder comments on President Trump’s executive order addressing extraterritorial taxation.

The Trump administration’s rejection of multilateral tax deals has strengthened the resolve of nations driving negotiation of a new tax treaty at the United Nations, while forcing others to rethink their strategies.

Mindy Herzfeld examines existing and recent proposed U.S. legislation that would apply retaliatory measures against other countries’ discriminatory or extraterritorial taxes.

Larissa Neumann, Mike Knobler, and William R. Skinner review the large amount of guidance released at the end of the Biden administration, including guidance on cloud computing transactions, disregarded payment loss regulations, and several chief counsel advice documents.

The EU will not deviate from its course regarding pillar 2 but would enter any possible OECD talks on a permanent safe harbor for U.S. companies with an open mind, Tax Commissioner Wopke Hoekstra said.

After days of deliberation, countries finally agreed to make decisions on a U.N. tax framework convention by simple majority, with a two-thirds majority needed to approve any protocols to the convention.

Implementing a mandatory high-tax exclusion so global intangible low-tax income would apply only to income below the exclusion threshold could reduce tax avoidance, raise revenue, and be relatively simple to implement, according to a February report released by the American Enterprise Institute.

Shuting Pomerleau compares two methods used to border-adjust a carbon price, arguing that border adjustments present unique challenges but, if designed well, would be an important part of a domestic carbon price in the United States.

Nana Ama Sarfo explains the prevalence of QDMTTs versus UTPRs in light of the Trump administration’s executive order and suggests the United States should consider implementing its own QDMTT.

Many countries — across income lines — said they would support dispute resolution and prevention as an early protocol to a U.N. framework convention on international tax cooperation.

China has targeted U.S. agriculture and natural gas with retaliatory tariffs after President Trump moved forward with tariffs on Chinese imports while pausing tariffs on imports from Canada and Mexico.

David J. Sotos and J.P. Gregorcy, in the first in a two-part series, examine the history of noncompulsory payment rules under reg. section 1.901-2(e)(5) and identify areas that need clarification in light of pillar 2.

The United States said it would withdraw from the entire U.N. process to negotiate a framework convention on international tax cooperation and encouraged other countries to join it.

The International Tax and Investment Center explains the concept of significant economic presence and shows the outcome of efforts by the OECD inclusive framework to develop a new net-basis taxation with parallels to the existing physical presence.

Canada's Department of Finance issued a release February 1 announcing that the government will impose 25 percent tariffs on U.S. goods worth C $155 billion in response to the U.S. tariffs imposed on Canadian products, noting that the government will continue to consider additional, non-tariff-related countermeasures.

EU member states have not yet resolved the issue of how to quickly introduce any future changes to the OECD's standard global anti-base-erosion information return, which is implemented through the administrative cooperation directive.

Negotiations for a U.N. framework convention on international tax cooperation are slated to begin in February, and key organizational decisions could further alienate EU member states that do not want to duplicate the OECD’s work.