Posted on
CBO Report Adds To Controversy Over Intl Tax Regs
The Congressional Budget Office's recent economic outlook report is murky on how the 2017 tax overhaul's international measures lowered corporate revenue projections by roughly $110 billion, leaving space for debate aboutwhether business-friendly regulations affected the adjustment.
Posted on
The OECD releases final TP guidance on financial transactions
The OECD has published its long-awaited TP guidance on financial transactions that includes several new points on how to apply the arm's-length principle (ALP) to credit default swaps and economic modelling.
Posted on
OECD Gig and Sharing Economy Platform Reporting Rules Take Shape
TheOECDis starting to design model rules governments can adopt to ensure sharing and gig economy platform operators report seller details in a consistent manner to tax administrations ÔøΩ and is asking for input.
Posted on
EU Adds 4 Jurisdictions to Blacklist, Adopts VAT Measures
Finance ministers added four jurisdictions to the EU list of noncooperative jurisdictions for tax purposesand adopted severalVAT-relatedtexts.
Posted on
EU Not Working on Plan B for Global Tax Deal Yet, Gentiloni Says
The EUwill enact a plan B if countries can't agree on a global tax update by the end of 2020, but for now, it's fully focused on plan A, the EU's tax chief said.
Posted on
Turkey Faces Tax Blacklist If No Changes to Policy, Austria Says (1)
Turkey has until the end of the year to complywith European Union demands on tax transparency, or else risk being added to a list of countries that could face financial sanctions, according to Austrian Finance Minister Gernot Bluemel. The rules include bilateral agreements to automatically exchange bank informationwith EU members,which include Cyprus.
Posted on
OECD's Preliminary Economic Analysis Highlights Need for Pillar Two Information and Engagement 
In light of the OECD's preliminary analysis, the author discusses the issue of double taxation under the proposed Pillar Two rules.
Posted on
European Union Proposes to Amend Council Directives for Administrative Cooperation in Tax Matters (1)
The EU proposal includes measures thatwould expand existing information exchange and create new information disclosure rules.
Posted on
Insight: Pillar One of the OECD BEPS Action 1 - The Ambitious Time-Bound Goals
The OECD intends to reach a consensus on the Inclusive Framework by the end of 2020. In light of that goal, the author examines the Framework's concepts, disparate interpretations, andwhat needs to be done to achieve a consensus.
Posted on
Fixing Five Flaws of the Tax Cuts and Jobs Act
The author arguesthat TCJAis flawed in five importantways: itgenerates large deficits thatwill reduce the ability of the government to fund important priorities in the future; itmoves the tax system in a regressive direction;it decreases economic efficiency insomeways, moving the tax system away from optimal design principles; itmisses an opportunity to combat profit shifting by multinational companies, changing the character of the problem but leaving its scale largely undiminished; andintroduces new sources of complexity.Clausing thensuggests both short term and more fundamentalways to reform the tax code.
Posted on
Companies Shifted Deductions, Income to Maximize 2017 U.S. Tax-Rate Cut
Posted on
EU Ministers Hit Pause on Blacklisting Turkey as Tax Haven
European Union finance ministerswill give Turkey more time to agree to exchange bank information automaticallywith all EU members before putting them on the bloc's tax haven blacklist. On the other hand, the economic bloc plans to put the Cayman Islands on its tax haven blacklist on Tuesday, February 18.
Posted on
OECD Clarifies How Companies Should Price Financial Transactions
Posted on
Insight: India Budget 2020Tax Measures Affecting Nonresidents
The authors look at the proposals for nonresidents announced in the India Budget 2020, including a tax on the digital economy and mandatorywithholding on digital transactions,whichwill have a significant impact on cross-border transactions.
Posted on
Tech Groups Wants to Help to Avoid Cloud Transaction Tax Hit
Business groups and tech giantswant the IRS to clarify new cloud computing tax rules and ensure companieswon't take an unexpected tax hit.
Posted on
Insight: U.K. Tax Authority Focus on "Profit Diversion" Means MNEs Pay More Tax
The authors consider the impact of the U.K. tax authority's Diverted Profits Tax so far, andwhat's ahead for multinationals.
Posted on
Luxembourg Company Scores Tax Victory in Canadian Court
A Luxembourg entity that owned a Canadian shale oil company and admitted involvement in a tax avoidance transaction has prevailed over allegations by the Canadian government that itwasn't entitled to treaty benefits.
Posted on
OECD Global Tax Overhaul May Lead to $100 Billion Revenue Spike
The two-pillar solution to update international tax rules for the digital age that's being considered by nearly 140 countries is projected to raise $100 billion annually in corporate tax revenues ÔøΩ but that estimate comeswith caveats.
Posted on
Repeal of Indian Dividend Tax Likely, Practitioner Says
Evenwith pushback from domestic investors, there is a high likelihood that the proposal to repeal India's dividend distribution tax (DDT)will pass in Parliament, a practitioner said.
Posted on
FASB Plans More Analysis of Income Tax Disclosure Requirements
TheFinancial Accounting Standards Board's pending decision on disclosure requirements for disaggregating income taxes may involve a balancing act,weighing investors' benefits against additional costs that companies might incur.
Posted on
Senate Dems Introduce Bill Blocking GILTI High-Tax Exception
U.S. multinational corporations could see new restrictions on foreign tax credits under legislation being pushed by twoSenateDemocrats.
Posted on
OECD Digital Tax Work a Priority for United States, Mnuchin Says
The United States has indeed reached a détentewith France over digital taxation and is pushing ahead at theOECDon a global solution to modernize the corporate tax system,TreasurySecretarySteven Mnuchinsaid. Speaking during a February 12Senate Finance Committeehearing,Mnuchinprovided confirmation ofnews in Januarythat the United States and France reached a settlement regarding the latter'sdigital services tax, on the sidelines oftheworld Economic Forumin Davos, Switzerland.
Posted on
EU adds Cayman Islands to Tax Haven Blacklist
The Cayman Islandswill join Oman, Fiji, and Vanuatu on an EU blacklist of foreign tax havens, making it the first UK overseas territory to be named and shamed by Brussels for failing to crack down on tax abuse.
Posted on
DSTs May Require Budding Friendship for Tax and Trade
The tax and trade communities in the United States, Canada, and Mexicowill have towork closely together to successfully navigate the road ahead on taxation of the digital economy, a KPMG tax partner said.
Posted on
Groups Suggest Fix for Cloud Regs Digital Content Source Rule
Treasury's proposed rule for sourcing sales of digital content is unworkable and should be revised to allow taxpayers to source those sales to the billing location of the first unrelated purchasing entity, according to several industry groups.
Posted on
Taxing Digital Giants Key to Restoring Capitalism, Le Maire Says
Capitalism needs a revolution, and fair taxation of major digital companies could play a big role in restoring capitalist values, according to French Finance Minister Bruno Le Maire.
Posted on
U.K. Opens Consultation on Global Tariff Proposal
The U.K. Department for International Trade has announced the opening of a public consultation on the country's first independent global tariff policy in nearly 50 years. Commentswill be accepted through March 5.
Posted on
Businesses Propose Switch to Consolidated Data for CbC Reporting
Businesses have told the OECD that the use of consolidated data for country-by-country reporting under the base erosion and profit-shifting projectwould be more straightforward than aggregated data.
Posted on
OECD's Pillar 2 May Yield Modest Revenue, Study Finds
The OECD digital tax plan's minimum tax proposal departs from the base erosion and profit-shifting project's policy consensus, and its effect on tax revenue could be modest, according to a new report.
Posted on
Economic Analysis: Are Royalties Paid to Tax Havens Indicators of BEPS?
The OECD has suggested that an inordinately high ratio of royalties received relative to research performed is an indicator of profit shifting. It asked for comment, and business commentatorswere highly critical. Still, data on royalties received provide important if inconclusive evidence about international tax practices.
Posted on
MNEs react well to Indias repeal of DDT and faceless appeals
The removal of the dividend distribution tax (DDT) could encourage foreign companies to expand their operations in the country, although there is some nervousness around the proposed faceless appeals.
Posted on
How Trump's Tariff Threats Are Hustling Global Tax Reform
Washington and Brussels have stepped back from the Trans-Atlantic battle over corporate taxation butwill face tough decisions in the second half of 2020.
Posted on
OECD's Global Tax Overhaul Too Cautious, Trade Union Group Says
The profit reallocation proposal in the OECD's plan for a global tax overhaul is too complex andwouldn't go far enough in reforming current international tax rules, the Trade Union Advisory Council to the OECD said.
Posted on
Insight: Highlights of the OECD/Inclusive Framework's Jan. 31 Statement on Pillars One and Two
The OECD issued a statement (30-page document) lastweek on the status of the Inclusive Framework's efforts on tax challenges of digitalization. The author discusses the key takeaways from the document.
Posted on
More Unilateral Taxes Likely if OECD Talks Fail: German Official
A German official said he is optimistic that nearly 140 countrieswill come to some conclusion this year on the OECD's global tax rewrite. But if talks fail to produce an agreement by December, countries considering plans for unilateral digital taxesÔøΩor ones that have paused collecting the tax, as France hasÔøΩwill likely move aheadwith those measures, said Christian Schleithoff, head of the financial division at the German embassy inwashington.
Posted on
EU Tries to Bind U.K. With Strict State Aid, Tax Standards
The European Commissionwants to bind the U.K. to strict state-aid and tax rules in the post-Brexit era, calling for the EU to be handed special rapid-response powers if it thinks Britain unfairly upends fair competition.
Posted on
INSIGHT: Possible Double Taxation Behind the Italian Digital Services Tax
The authorsanalyze the new Italian digital services tax and explain their concerns over its relationshipwith the OECD Unified Approach.
Posted on
House panel to hold hearing examining GOP tax law regulations affecting corporations
The Houseways and Means Committee on Tuesday announced that it is set to hold a hearing nextweek titled "The Disappearing Corporate Income Tax," as Democrats have expressed concerns about the amount of taxes large companies are paying under President Trump's 2017 tax-cut law.
Posted on
Int'l Income Allocation Rules Outdated, OECD Tax Chief Says
The rules for allocating profits among jurisdictionswhere multinationals operate are no longer fit for purpose, the head of the Organization for Economic Cooperation and Development's tax policy center said on Tuesday.
Posted on
Foreign Cos. Push For Full Repeal Of Internal Debt Rules
A group representing foreign-parented companies doing business in the U.S. has urged the U.S. Treasury Department to repealwhat remains of the Obama administration's earnings-stripping rules.
Posted on
EU Calls for Strong U.K. Commitment to State Aid, Tax Standards
Any EU-U.K. trade deal should "uphold the common high standards" in such areas as state aid and tax to curb unfair trade and competition distortions, according to a draft EU negotiation mandate.Michel Barnier, head of the European Commission's task force for relationswith the United Kingdom, presented the outline for opening trade talkswith the United Kingdom on February 3, after the country officiallywithdrew from the bloc January 31.
Posted on
Time Running Out for OECD Consensus With Unilateral DSTs on Rise
Tax and trade officials say the OECD may be unable to achieve consensus by the end of the year on its plan for addressing the digital economy unless countries become more open to compromise.
Posted on
U.K. Corporation Tax Rate Cut May Help Boost Post-Brexit Growth
Some U.K. tax policy measures, such as cutting the corporate tax rate and introducing a regional corporation tax system, could give the United Kingdom a boost after Brexit, a new report says.
According to research from A&M Taxand and Capital Economics, published February 4, the U.K. government has several options at its disposal to ensure U.K. competitiveness and economic growth, now that it is no longer a member of the EU.
Posted on
What Is the Value of Users, Anyway? How to Value the User Contribution to Digital Enterprises
In this article, the authors consider the economics of digital businesses and the value of user contribution, including through active engagement and the provision of data, to those entities. After considering several options, they propose a framework for estimating the taxable value that users in market countries bring to digital platforms based elsewhere.
Posted on
Don't Stop the BEAT
The base erosion and antiabuse tax provisions added by the Tax Cuts and Jobs Act have several ambiguities that require an inquiry into the original intent of the BEAT. This article seeks to aid courts, scholars, regulating authorities, and legal professionals looking to understand this international tax provision and the concept of base erosion, by examining multiple factors such as its structure, legislative history, international tax principles, and the BEAT's similarities to recent international tax trends ÔøΩ like the OECD's global anti-base erosion proposal (pillar 2) or the digital services minimum taxes around the globe.
Posted on
Brexit (and Megxit) Predictions
Lee A. Sheppard looks at the consequences of the United Kingdom's exit from the European Union, focusing on how the transition periodwillwork.
Posted on
Want a Pillar 2 Exemption? Get in Line
Mindy Herzfeld examines comments the OECD received on its pillar 2 global minimum tax, noting thatdespite the array of commentators, the requests tended to focus on an exemption from the tax.
Posted on
Economic Analysis: A Simple Explanation of the Sophisticated Case for Digital Taxes
Martin A. Sullivan agreeswithwei Cui'swork on international tax that, among other things, hasstriking implications for digital service taxes.
Posted on
Global Tech Tax Gains Steam After Nations Set December Goal
The threat of a new transatlantic tradewar diminished after 137 countries agreed to continue negotiations aimed at creating rules for taxing multinational technology companies that receive foreign revenue.
Posted on
Global Corporate Tax Avoidance Might Get Harder
An effort to coordinate international taxationwill end many of the old dodges.