Int'l Tax News

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.

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

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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

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.

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.

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.

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.

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.

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

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.

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.

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.

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

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.

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.

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.

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.

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

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.

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

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.

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.