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Int'l Tax News

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EU Considering New Rules on Tax Evasion, Digital Taxation

  • By Isabel Gottlieb

The European Commission is planning new anti-tax evasion rules, plus a communication on updating corporate taxation, to be released in the second quarter of 2020.

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Europe Mulls Several Carbon Border Tax Options, Official Says

  • By Ewa Krukowska

The European Commission is considering several options for penalizing imports from polluters, amid ever-louderwarnings that the plan could trigger retaliation from China and the U.S.

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Denmark Support EU-Wide Deal on Digital Tax, Premier Says

  • By Morten Buttler

Danish Prime Minister Mette Frederiksen told an EU conference in Copenhagen that Denmarkwould support an EU-wide agreement to the digital tax controversy should a global deal fail.

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Insight: U.K. Final Regulations for Disclosure of Cross-Border Tax Arrangements

  • By Catherine Robins

The author reviews the U.K.'s recently issued final regulations to implement the EU directive DAC 6,which is designed to enable EU tax authorities to share information about cross-border tax schemes. The regulations require U.K. tax intermediaries to report to HM Revenue and Customs certain cross-border tax arrangements.

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Anti-Abuse Law Helps Bring U.K. $6.5 Billion More Corporate Tax

  • By Hamza Ali

While the U.K.'s diverted profits tax is raising less revenue than expected, according to newly released data, it may beworking as it should.
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Insight: Weapons of Mass Taxation - Excise Taxes, Transfer Pricing and Tariffs

  • By Steven C. Wrappe

The author discusses the three different taxing approaches that have emerged to address the tax challenges of the digital economy.

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Mnuchin warns UK, Italy of tariffs if digital tax plans are implemented

  • By Naomi Jagoda

Treasury Secretary Steven Mnuchinwarned the United Kingdom and Italy that theywill face tariffs if they move forwardwith digital tax plans, Thewall Street Journal reported Tuesday.

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France's Le Maire Rejects US Safe Harbor Plan On Global Tax

  • By Todd Buell

French Finance Minister Bruno Le Maire on Friday rejected a controversial U.S. plan to structure a proposed new international tax as a safe harbor, towhich companies could opt in or out

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Int'l Tax Overhaul Not Adding Complexity, OECD Tax Chief Says

  • By Matt Thompson

The Organization for Economic Cooperation and Development's head of tax recently hit back at criticism that current international tax reform effortswill increase the complexity of the global tax system, saying the current rules are anything but simple.

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Investor Group Calls For Broader Financial Transaction Tax

  • By Najiya Budaly

Europe should extend its proposed tax on financial transactions to include the currency market, a "privileged playground" that trades more than $5 trillion every day, to make financial institutions pay their share of the tax, a consumer group said Tuesday.

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US Threatens UK With Tariffs Over Digital Services Tax

  • By Matt Thompson

U.S. Treasury Secretary Steven Mnuchin has threatened tariffs on U.K. imports if Britain doesn't back down on its pledge to enact a digital services tax starting in April, following a recent simmer in trade tensions between the U.S. and France.

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US Safe Harbor Plan Not 'Credible,' French Official Says

  • By Alex M. Parker

French Finance Minister Bruno Le Maire onwednesday blasted a U.S. proposal to implement a new global tax as an optional safe harbor, claiming it is not "credible" as a starting point in international negotiations on taxing the digital economy.

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Australia Tax Office Reviewing Intangible Asset Arrangements

  • By Eli Flesch

The Australian Taxation Office onwednesday said it's reviewing international business arrangements to determinewhether they are made at arm's length and don't mischaracterize activities connectedwith intangible assets.

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Shells Public Tax Report Signals Broader Transparency Trend

  • By Natalie Olivio

Publication of the oil company Shell's global tax information could provide an example for other businesses to follow as the call for corporate transparency reaches a crescendo,with mounting pressure from investors and the recent launch of public reporting standards.

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135 European Parliament Members Call For Unitary Taxation

  • By Todd Buell

A multiparty group of European Parliament members has told U.S. lawmakers it's time to shed the arms-length principle, long used as the standard for allocating income among members of multinational businesses, and move to a form of unitary taxation.

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Countries competing over taxing rights raises TP scrutiny

  • By Josh White

Tax authorities competing against each other over taxing rights means taxpayers are dealingwith more scrutiny over their transfer pricing (TP) arrangements because no onewants to accept defeat.

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OECDs digital tax plan will be a menu of options for nations

  • By Anjana Haines

A new international standard on how to tax the digital economywill leave taxpayers and their advisors battling more asymmetrical tax laws around theworld, according to lawyers speaking at a conference.

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Mnuchin Warns U.K., Italy Over Digital-Tax Plans

  • By Greg Ip and Paul Hannon

After France agreed to delay its digital tax int he face of steep U.S. tariffs on french products, Treasury Secretary Steve Mnuchinwarned that Italy and Britainwill face U.S. tariffs if they proceedwith a tax on digital companies.
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Carbon Tax Won't Be Necessary Due to Technology, Mnuchin Says

  • By Jill Ward

Going against the consensus at this year'sworld Economic Forum in Davos,U.S. Treasury Secretary Steven Mnuchinweighed in on the debate about a carbon tax in Davos, saying technological developmentswould make it redundant.

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After France Truce, U.S. Faces New Tech-Tax Threat in Europe

  • By Krystof Chamonikolas

After France has agreed to delay a 3% digital tax until the end of the year, the Czech Republic is debating imposing a 7% tax on global internet companies, brushing aside possible U.S. retaliation.

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U.S. to Fight Back if Nations Discriminate on Digital Tax: Ross

  • By Jonathan Ferro and Jenny Leonard

In an interviewwith Bloomberg Television, in referring to France's 3% digital services tax, U.S. Commerce Secretary said "It is clear that this is a protectionist and discriminatory proposal thatwas made" and, "if there is discriminatory behavior,wewill fight back."

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EU Warns China to Price Carbon or Face Tax on Trade, FT Says

  • By Mathew Carr

President of the European Commission Ursula von der Leyenwarned China and other fossil fuel producers to put a price on carbon emissions at home or risk beingwith a planned greenhouse gas tax on imported products.

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France Say's U.S. Agreed on a Path To Global Tech Tax Accord

  • By William Horobin and Saleha Mohsin

While speaking at theworld Economic Forum in Davos, French Foreign Minister Bruno Le Maire said that U.S. Treasury Secretary Steve Mnuchin has agreed to drop a U.S. demand that digital services taxes be optional.

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France's Le Maire Says in Good Mood for Talk With U.S.

  • By Francine Lacqua and William Horobin

French Finance Minister Bruno Le Maire said he is hopeful for a compromisewith the U.S. on digital taxes to avoid a transatlantic tradewar.
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Javid Says U.K. Plans to Go Ahead with Digital Tax in April

  • By Lucy Meakin

At theworld Economic Forum in Davos, Chancellor of the Exchequer Sajid Javid told a panel that the U.K. government intends to go ahead tax on digital services in April. The taxwill be temporary and last until an international agreement is put in place.
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Why 'Digital Taxes' Are the New Trade War Flashpoint: QuickTake

  • By William Horobin and Aoife White

Reporterswilliam Horobin and Aoifewhite succinctly summarize how digital taxes have become the new front for an ongoing global tradewar.

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EU Countries Push for Carve-Out in OECD Global Minimum Tax

  • By Joe Kirwin

Estonia, the Czech Republic, and Poland are asking for an exemption for some companies from the OECD-led effort to set a global minimum tax rate.

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GLOBE: A Process in Search of a Purpose

  • By Mindy Herzfeld

Mindy Herzfeld examines public comments that criticize the lack of direction in the OECD's pillar 2proposals, saying itwould bewise for the organization to slow its aggressive timeline for consensus on howto address the digital economy.

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Beat the BEAT, Part 2: Partnership Antiabuse Rule

  • By Carrie Brandon Elliot

Carrie Elliot reviews how the proposed BEAT regulations apply to partnerships.

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OECD Global Tax Deal Talks Back on Track After France-U.S. Spat

  • By Stephanie Soong Johnston

France may have announced the United States is no longer pushing for a global tax overhaul to beoptional for companies, but that doesn't really change much in ongoing negotiations, the OECD's tax chiefsaid.

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Safe Harbor Proposal Reflects Political Concerns, Harter Says

  • By Ryan Finley

U.S. Treasury Secretary Steven T. Mnuchin's surprise proposal to make pillar 1 of the OECD's digitaleconomy project electivewas driven by doubt that Congresswould approve a mandatory regime, accordingto Treasury's top international tax official.

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France, U.S. Find Common Ground for OECD Digital Tax Progress

  • By Stephanie Soong Johnston

France and the United States are making progress in OECD-led negotiations on a solution tomodernize international corporate tax rules by the end of 2020 ÔøΩ but morework remains, a top Frenchofficial said.

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U.S. Could Hit Back at Tech Taxes With Car Tariffs, Mnuchin Says

  • By Stephanie Soong Johnston

If countries insist on imposing arbitrary taxes on American digital companies, the United States couldrespond by levying tariffs on their automobiles, U.S. Treasury Secretary Steven Mnuchinwarned.

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Global Tax Deal Won't Hinge on U.S. French Spat: OECD Official

  • By Hamza Ali and Rick Mitchell

Teaser: The OECDwill move aheadwith an effort to overhaul how the digital economy is taxed even if France and the U.S. fail to resolve their dispute over a French digital services tax.

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IRS Eyes Help, Not Guidance, for Double Tax on Repatriated Cash

  • By Siri Bulusu

The IRSwill provide relief in the form of private letter ruling or closing agreement to taxpayerswith repatriated earnings that are taxed twice under Section 965.

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Tax Executives Ask OECD to Narrow Scope of Global Overhaul

  • By Hamza Ali

Tax executives havewarned the OECD that efforts to rewrite global tax rules are too broad andwould likely affect businesses that have not engaged in profit-shifting.

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Economic Analysis: 25 Years of U.S. Multinational Foreign Investment, Income, and Taxes

  • By Martin Sullivan

In economic analysis, Martin A. Sullivan explores just how much profit shifting into tax havens hasincreased over time.

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E.U. Will Back France Against U.S.-Imposed DST Tariffs

  • By Annagabriella Colon

European Commissioner for Trade Phil Hogan said the EUwill present a united front against tariffsthe United States plans to impose on France in response to its digital services tax.

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BEPS Has Caused Spike in Transfer Pricing Dispute, OECD Told

  • By Santhie Goundar

The OECD's base erosion and profit-shifting project has increased the number of transfer pricingdisputes, according to members of a panel discussing the strengthening of dispute avoidance and resolutionmechanisms.

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Simplicity in Digital Economy Solution May Cause Harm

  • By Santhie Goundar

While acknowledging that the current proposal for a minimum tax under pillar 2 of the OECD's projecton digital economy taxation lacks key details, an OECD official urged caution in seeking a solution focusedon simplicity.

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U.S. Sanctions Won't Make France Drop Digital Tax, Le Maire Says

  • By Stephanie Soong Johnston

Punitive U.S. tariffs on French goodswon't convince France to abandon its digital services tax, butagreement on a global tax deal at the OECDwill, French Finance Minister Bruno Le Maire said

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Extended CFC Look-Through Rules Will Cost $700M, CRS Says

  • By Joseph Boris

Look-through rules,which govern the taxability of payments between U.S. controlled foreign corporations andwhichwere extended in budgetary legislation enacted in December,will cost the federal government $700 million, the Congressional Research Service has said in a report.

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Trump Administration Backs Brazil's Inclusion In OECD

  • By Joseph Boris

President Donald Trump's administration saidwednesday it is supporting Brazil's bid to join the Organization for Economic Cooperation and Development, asserting that the country isworking toward policies that meet OECD standards.

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Unity Helps Boost Nations' Tax Powers, OECD Tax Chief Says

  • By Matt Thompson

Countries can strengthen their ability to collect tax revenue by acting multilaterally in away that limits their sovereignty, Pascal Saint-Amans, head of tax policy at the Organization for Economic Cooperation and Development, said Thursday at a conference in Berlin.

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Tax nationalism goes to the World Economic Forum

  • By Josh White

After months of tensions, French and US officials are set to meet face-to-face at theworld Economic Forum (WEF) nextweek to try and end the row over international taxing rights.

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Did the U.S. Tax Overhaul Do What It Promised?

  • By Richard Rubin and Theo Francis

Richard Rubin and Theo Francis broadly review the effects of the Tax Cuts and Jobs Act.

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A New Global Tax Deal for the Digital Age

  • By Allison Christians and Tarcisio Diniz Magalhaes

The OECD is currently in the midst of a project intended to tackle the tax challenges arising from the digitalization of the economy. As laid out in Pillar 1 of its program, the goal seemed, broadly, to develop consensus on a new taxing right and to allow countries to tax multinationals even in the absence of traditional physical presence.Part I of the authors' article beginswith a brief survey of some of the main factors that prompted the OECD to turn its attention to this topic. They continue on to Part II inwhich they consider the origins and development of nexus in the international tax regime and showwhy this concept is amenable to broad expansion. In Part III, the authors then examine the range of reforms currently under consideration; they argue that the framing on digitalization misses a necessary connection to other pressing international policy programs that are also under development, specifically, a global commitment to building institutions that support sustainable economic development. Finally, they concludewith a prediction that on its current trajectory, the program ofwork on digitalization is likely to produce a new global tax deal that looks much like the old global tax dealwith a relatively modest redistribution of taxing rights among a few key states.

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IRS May Consider Relief From Double Tax on Repatriated Cash

  • By Siri Bulusu

The IRS has opened an informal process that may offer relief to companies that pay tax twice on the same repatriated earnings.

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Debate on Foreign Tax Disclosure Returns to Spotlight

  • By Nicola M. White

Financial Accounting Standards Board Chairman Russell Golden told lawmakers that the Boardwill debatewhether companies must detail tax payments to individual countries by the end of the first quarter.

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German Finmin to Pitch Financial Transaction Tax in <4 Weeks: HB

  • By Alexander Pearson

German Finance Minister Olaf Scholz intends to present a draft for a national financial transaction taxwithin the next month in the event that the ongoing negotiations for an EU-wide tax fail.

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