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U.K. Should Delay Digital Tax Amid Pandemic, Tech Group Says
The U.K. digital services tax might be in effect, but it should be suspended to give companies grapplingwith the COVID-19 crisis some relief, a tech trade group representative said.
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'Favorable' NOL Carryback Rules Apply to Deemed Repatriations
Multinational businesseswith prior years' deemed repatriation income maywant to take advantage of the special net operating loss carryback rules in the coronavirus stimulus package, a practitioner says.
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More Trade Groups Call for OECD Tax Overhaul Delay During Crisis
Two more industry groups are dialing up the volume on calls to their respective governments to delay the timeline of theOECD'swork on a global corporate tax overhaul in light of the coronavirus pandemic.
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Electing Out of Interest Limitation Changes Could Save on BEAT
Not all taxpayerswillwant to take advantage of the changes to the interest deduction limitation in the latest round of coronavirus legislation, according to a practitioner.
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UK Seeks To Force Big Cos. To Report Uncertain Tax Positions
The U.K. tax authority began seeking public input on a proposed rule to require large businesses to notify itwhen taking an uncertain tax position they believewill be challenged.
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HMRC Seeks Info On Effects Of OECD's Anti-Abuse Rules
HM Revenue & Customs issued a consultation to determinewhether new rules meant to prevent companies from manipulating differences in national tax systems may hit some legitimate lending relationships.
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UK Issues Guidance for Digital, Corporate Tax Overlap
The U.K. government published guidance to help multinational companies navigate placeswhere the country's digital services tax interactswith other corporate tax measures, including transfer pricing rules and similar digital levies overseas.
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OECD Faces Hard Deadline On Digital Taxes, Despite COVID
Tax officials from around theworld face immense pressure to negotiate an overhaul of the international tax system at the OECD by the end of the year, even as the coronavirus pandemic brings mostwork around theworld to a halt.
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US FDII is still too complex to claim, say companies
Taxpayers are having to go to "extreme lengths" to claim the foreign derived intangible income (FDII) deduction under US tax rules. One tax director at a medical device company talks to ITR about the challenges.
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Swedish Court Denies FLIR $200 Million Notional Tax Deduction
A Swedish court has ruled against thermal camera producerFLIR Systemsin a dispute concerning an intangible transfer to a Belgian branch, holding that the tax agency correctly denied a group subsidiary's notional tax deduction.
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India Expands Equalization Levy Net to Tax Foreign E-Commerce
Nonresident e-commerce operatorswill now have to pay a 2 percent tax on revenues from the sale of goods and services to Indian consumers, after the government broadened the scope of its equalization levy regime.
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CARES Act Has Negative Knock-On' Effects for International Tax
Practitioners are discovering that business-friendly changes to net operating losses and interest deduction limitations in legislation responding to the coronavirus economic crisis could also adversely affect multinationals because of interactionswith other international provisions.
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Helping Loss Companies: What Can Treasury Do?
Mindy Herzfeld examines U.S. Treasury options for alleviating the economic blowback of the coronavirus pandemic, questioningwhether further relief has been left on the table.
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Germany Introduces Long-Overdue R&D Tax Incentives
In this article, the authors discuss newly introduced research and development tax incentives in Germany, focusing on eligibility requirements, determination of tax relief, and international cooperation.
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Software Service Income Not Technical Service Fees, Court Say
Payments to an Australian company for supplies of software services do not qualify as fees for technical services but should be further examined to determine if they qualify as royalties, theDelhi High Courtheld.
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Russian Coronavirus Relief Plan Could Threaten Tax Treaties
Prime MinisterMikhailMishustin said Russia maywithdraw from its tax treatieswith specific countries that refuse to impose a 15 percent tax on individuals transferring their dividend income abroad.
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U.S. Group Pushes Delaying OECD Digital Tax Work Amid Pandemic
Treasuryshould postpone theOECD'swork on updating global corporate tax rules for the digital age as companies and governments continue grapplingwith the economic fallout of the coronavirus crisis, a major trade group said.
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The NOL Carryback That Isnt, and the Worthless NOL That Is
In this article, Eric M. Lopata of Prudential Financial Inc. explainswhy a net operating loss carryback provision in the COVID-19 relief legislationwill not have the intended stimulus effect unless Congress also addresses a problem caused by the application of the NOL computation rules to taxpayerswith global intangible low-taxed income.
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India Delays Tax Filing Deadlines Amid COVID-19 Pandemic
India has announced relief measures thatwill extend the filing deadline for income tax and goods and services tax returns, provide relief under the tax dispute scheme, and lower interest rates fordelayed tax payments.
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OECD Sets Out First-Aid Tax Measures Amid Growing Pandemic
TheOECDhas outlined emergency tax measures that governments can adopt to respond immediately to the economic fallout of the coronavirus pandemic, sending a clear message: Dowhatever you can now to keep taxpayers afloat.
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Australian Research and Development Bill Faulted for Encouraging Foreign Competition
AnAustralian Senatecommittee is considering legislation to reform research and development tax initiatives that critics say islargely unchanged from a set of measures that failed to passwhen first proposed in 2018.
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Canada's High Court Dismisses Amazon Appeal
The Supreme Court of Canadahas dismissed an appeal byAmazon Inc., a major victory for customerswho claim the company charged sales taxes thatweren't due.
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U.S. COVID-19 Bill Hits Company International Tax Fix Wish List
Buried deep in the pages of aSenatebill to provide economic relief from the coronavirus pandemic are long-awaited Tax Cuts and Jobs Act technical corrections on transition tax overpayment and downward attribution.
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OECD Outlines COVID-19 Emergency Tax Measures for Governments
The OECD has outlined several tax measures that countries can take to respond immediately to the economic fallout of the coronavirus pandemicwith a clear message to governments: Dowhat you can to help taxpayers.
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HMRC May Relax Anti-Hybrid Rules Amid Wider Antiavoidance Effort
AsHM Revenue & Customsprepares to implement a series of new measures targeting tax avoidance schemes, the agency has signaled its openness to amending aspects of the hybrid mismatch rules criticized as disproportionate and overbroad.
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Taxable Presence and Highly Digitalized Business Models
In this article, the authors discuss how the digitalization of the economy is affecting nexus rules and analyze international tax treaty law on permanent establishment and the taxable presence of digital businesses.
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OECD Global Tax Overhaul Work on Track Amid COVID-19 Crisis
Despite the growing coronavirus pandemic, theOECDsecretariat is stillworking "full steam" ahead on a solution to update the international tax rules for the 21st century ÔøΩwhile using digital methods.
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EU to Ease State Aid Rules to Support Businesses
TheEuropean Commissionhas proposed thatbusinesses affected by the coronavirus be allowed to receive direct grants and selective tax advantages of up to ÔøΩ500,000 to address urgent liquidity issues.
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Trade Groups Seek Tariff Relief to Reduce Coronavirus Impact
Over 20 U.S. trade groups are calling on the Trump administration to eliminatesection 301tariffs, saying it is the onlyway to provide immediate relief from the financial burden of the coronavirus.
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Big 4 Firms Throw Their Weight Behind Altera's Supreme Court Bid
Three of theBig Four accounting firmshave added to calls forthe Supreme Courtto reviewAltera, arguing in an amici brief that the commensuratewith income standard cannot justify the 2003 cost-sharing regulations.
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Ireland Fears Corporate Tax Revenue Hit From OECD Proposals
Irish tax revenues reached their highest level last year at approximately ÔøΩ60 billion, but theOECD's international tax proposalswill increase uncertainty and volatility in corporation tax receipts in the coming years.
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Tech Giants Warn Supreme Court of Alteras Staggering Effects
Citing a $5 billion increase in aggregate tax liability following theNinth Circuit'sAlteradecision,Cisco Systemsand other high-profile tech companies have filed an amici brief supportingAltera's petition forSupreme Courtreview.
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Global Crises and Loss Planning
Using the coronavirus pandemic as a backdrop, Mindy Herzfeld reviews legislative and administrative actions during and since the 2008 financial crisis, noting that antiabuse tax ruleswritten in times of global profit and economic growth can have adverse effects in a downturn.
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Governments Worldwide Propose Tax Breaks to Counter Coronavirus
As the coronavirus extends its potentially deadly reach throughout theworld, severalcountries have announced tax and other measures to mitigate the economic impact from theCOVID-19disease.
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Polish Forum Endorses OECD Alignment on Transfer Pricing Methods
An advisory forum to thePolish Ministry of Financehas recommended that the country's new rules on transfer pricing methods be applied in accordancewithOECDguidance on the transactional net margin and resale-price methods.
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U.K. Budget Confirms DST Plans, Cuts Entrepreneurs Relief
The capital gains tax entrepreneurs' relief is expensive, ineffective, and unfair, U.K. Chancellor of the ExchequerRishi Sunakdeclared as he announced a substantial reduction in the lifetime limitwith immediate effect.
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The Arbitrary Foreign Tax Credit
ProfessorsJordan M. Barry and Ariel Jurow Kleiman discuss the development of the income tax limit to the foreign tax credit before describing the implementation and conceptual problemswith such a limit. They continue on to consider the arguments in favor of a narrow tax credit, before finally presenting the reform options for policymakers. Barry and Kleinman ultimately conclude that movingforward involves abandoning the credit's sharp, arbitrary distinction between pure income taxes and all other taxes.
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U.K. Holds Firm on Digital Tax in Virus-Dominated Budget
The U.K. government is maintaining its commitment to introduce a digital services tax in threeweeks.
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AstraZeneca Warns Public Global Tax Reports Could be Misread
Business groups and companies including AstraZeneca are pushing back against calls from U.S. lawmakers and advocacy groups to make corporate global tax reports public,warning that publishing such data could harm them.
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Insight: OECDs Alarm on Coronavirus and the World EconomyWhere Do Pillars 1 and 2 Fit In?
The author discusses how he believes the OECD's proposals under Pillars One and Two to increase corporate tax globally conflictwith the organization's recently issued economic assessment of the impact of the coronavirus on theworld economy.
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UK Gov't To Review Tax Regime For Funds To Boost Appeal
The government saidwednesday itwas looking forways to boost the attractiveness of the U.K. as a place for fund managers to establish themselves, including removing tax barriers that hold companies back from setting up.
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TCJA Transition Tax Raised $140B In 2017, IRS Says
More than 3,200 companies reported approximately $140 billion in tax obligations during 2017 related to the Tax Cuts and Jobs Act's transition tax provision, the Internal Revenue Service has reported.
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Public CbCR debate taken to the OECD
If the OECD adopts suggestions to align country-by-country reporting (CbCR)with the Global Reporting Initiative (GRI) standard public CbCRwill be inevitable, but this did not stop organisations expressing their opinions.
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EU Seeks Feedback On Measures To Fight Tax Fraud
The European Commission onwednesday asked for comments over the next fourweeks on an action plan to fight tax fraud as it prepares to make a more definite announcement in the summer.
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US, Mexico Renew Advance Tax Agreement For Manufacturers
The U.S. and Mexican tax authorities have renewed their agreement on a framework allowing more than 650 manufacturing companies to obtain certainty from the Mexican government about their taxes, an Internal Revenue Service official said Thursday.
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Brazil returns to the arms-length principle
As Brazil embraces OECD standards, many countries are moving in the opposite direction. This seismic shift in the largest South American economy could mean that Brazilwill remain an outlier in global tax policy.
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Amazon fights to overturn EU state aid ruling
The US technology company is battling against the European Commission's finding that its past cost-sharing arrangements in Luxembourg violated EU state aid law.
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The Fiat Appeal: Who Hijacked the Arms-Length Standard?
Robert Goulder examines the EU state aid case against Fiat and the implications it holds for Apple.
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Tech Groups Press Supreme Court to Review Altera
The financial and legal issues at stake inAltera Corp.'s cost-sharing challenge are too great forthe Supreme Courttowait for a circuit split, according to a group of trade and industry organizations.
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OECD Cancels Action 13 Public Consultation Amid COVID-19 Crisis
TheOECDhas called off an upcoming public consultation on its review of its country-by-country reporting standards under action 13 of the base erosion and profit-shifting project, citing growing coronavirus concerns.