Posted on
INSIGHT: The OECD Unified Approach√¢$an Indian Perspective
Suranjali Tandon of the National Institute of Public Finance and Policy, New Delhi, looks at the OECD Secretariat's "unified approach,"with a focus on the stancewhich has been taken by India so far, and the potential elements of the approachwhich may not be acceptable to India.
Posted on
U.S. Weighs Limits on Taxable Presence in Global Tax Rewrite
The U.S.wants the OECD's plan to revamp global tax rules to apply to more companies, but limit the countries that can tax them, a Treasury official said.
Posted on
IRS Wants to Help Companies Bring Intangible Assets Back to U.S.
The IRSwants to know how it can help companies that are looking to unwind pre-tax law transactions to bring intangible property back to the U.S., according to a top agency official.
Posted on
U.S. Companies" Repatriated Cash Hits $1 Trillion Under Tax Law
Corporations have brought back more than $1 trillion of overseas profits to the U.S. since Congress overhauled the international tax system and prodded companies to repatriate offshore funds, a report showed Thursday.
Posted on
Double Counting Accounting: How Much Profit of Multinational Enterprises Is Really in Tax Havens?
By Jennifer Blouin and Leslie A. Robinson
Putting an end to the base erosion and profit shifting (BEPS) activity of multinational enterprises (MNEs) is on the national agenda of nearly every country in theworld.while many influential papers suggest that the scope and magnitude of the BEPS problem is quite large,we show that these magnitudes are likely overstated due to the accounting treatment of indirectly-owned foreign affiliates in the BEA's U.S. international economic accounts data.we explain how this accounting treatment leads to double counting of foreign income and to misallocations to the incorrect jurisdiction.we demonstrate an appropriate correction, and show that the correction significantly reduces the magnitude of the BEPS estimates. For instance, our correction reduces an estimate of the U.S. fiscal effects of BEPS from 30-45% to 4-15% of corporate tax revenues lost to BEPS activity of MNEs (Clausing 2016). Ourwork has far-reaching implications, as the U.S.' national statistics have a unique accounting convention that can make comparisons of the U.S. national statistics to those of other countries difficult to interpret.
Posted on
A Critical Reassessment of the Role of Neutrality in International Taxation
By David Elkins
Neutrality plays a central role in the literature on international taxation. In its most prevalent form, the concept of neutrality posits that in order to maximize aggregate globalwelfare, capital needs to flow towhere itwould produce the highest pretax return. The thesis of this Article is that neutrality is ordinarily inapplicable in the field of international taxation.
Posted on
Corporations paid 11.3 percent tax rate last year, in steep drop under Trump's law
Ninety-one of America's biggest firms paid no federal taxes, the report found.
Posted on
Final Regs Narrow Two Sets of Subpart F Relatedness Rules
Carrie Elliot describes how final regulations narrow the Subpart F-related definition of related persons and the applicationof active rents exception for CFCs payments to property owners.
Posted on
OECD Aims to Publish Global Tax Reform Analysis in Early 2020
The OECD continuesworking on economic analysis and impact assessments of the pillar 1 and pillar 2 proposals thatcountries are considering and hopes to start publishing some findings in early 2020.
Posted on
Is the OECD's Project Salvageable?
Mindy Herzfeld examines alternatives to the OECD's pillar 1 proposal following a stepping back from the process by the United States
Posted on
U.S. Proposal for Pillar 1 Safe Harbor Sparks Concern
A pillar 1 safe harbor regime is not a path the OECD is actively pursuing, but it isn't precluding the option of a safe harborregime, according toan OECD official
Posted on
OECD Global Tax Pact Likely To Win Out Over Chaos
While muchwork remains on the Organization for Economic Cooperation and Development's new global taxing approach, a deal on reallocation of taxing rights and a minimum tax is likely because failure to agreewould cause chaos, an OECD official told Law360.
Posted on
Nations Remain Committed To Tax Reform, OECD Official Says
All members of the Organization for Economic Cooperation and Development inclusive framework on tax reform remain committed to the process, an OECD official told stakeholders attending a public consultation held Monday near Paris.
Posted on
10 EU Countries Nearing Deal On Financial Transaction Tax
A group of 10 European Union countries is approaching an agreement on a financial transaction tax, Germany's finance minister, Olaf Scholz, has said in a letter to fellow ministers.
Posted on
UK political parties clash over DSTs
The UK's political parties have taken different stances onwhether and how to introduce a digital services tax (DST) despite the threat of US retaliation.
Posted on
Brazil reveals 2020 tax reform proposals
The Brazilian government has announced that itwill start presenting proposals to congress to overhaul the country's complex tax system starting in 2020.
Posted on
U.S. Tax Cuts Drive Revenue Dropoff in OECD Countries: Report
Tax revenue as a percentage of GDP in OECD countries remained unchanged from 2017 to 2018, the first time in recent years that the ratio didn't increase, according to a report. Link:
Posted on
France to Seek Europe Tech Tax Deal If No U.S. Pact: Minister
If the U.S. cannot agree to a global deal on digital taxes, Francewill try for an agreementwith Europe, the French minister for digital affairs says on Bloomberg Television.
Posted on
INSIGHT: Taxing Multinationals√¢$The GloBE Proposal for a Global Minimum Tax
The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. Lorraine Eden of Texas A&M University provides a detailed analysis of the global minimum tax proposal, discussed its benefits and costs, and provides policy recommendations.
Posted on
EU Trade Chief Hogan, Lighthizer to Discuss French Tariff Threat
The European Union's chief trade negotiator Phil Hoganwill sit downwith U.S. Trade Representative Robert Lighthizer next month to discuss an American threat to hit Francewith tariffs on $2.4 billion of its exports.
Posted on
INSIGHT: Who is Afraid of the Digital Services Tax?
Professorwei Cui of the University of British Columbia looks at the attempts to introduce a new international tax framework, and considers how effective current proposalswill be in addressing the challenges posed by the digital economy.
Posted on
Spare High-Tax Business From OECD Global Tax Math: Rio Tinto
There is no point forcing all companies to do complex calculations proving they are outside the scope of proposed OECD minimum-tax rules, Rio Tinto's global head of tax said.
Posted on
Biden to Target Tax-Avoiding Companies Like Amazon with Minimum Federal Levy
Democratic presidential candidate Joe Biden plans to pay for $3.2 trillion in policy proposalswith new and higher taxes on thewealthy and corporations, including a measure targeting companies like Amazon.com Inc. and Netflix Inc. that have reported paying no federal income taxes in recent years.
Posted on
Italy's Drive on Corporate Back Taxes Reaps $2.6 Billion
Italy's claim that Fiat Chrysler Automobiles NV underestimated the value of its U.S. business is just the latest installment in the country's campaign to reap billions of euros in unpaid taxes from multinational corporations.
Posted on
Biden's Tax Plan Is Better Than It Looks
It is realistic and makes an honest effort to limit any negative impact on economic growth.
Posted on
France's Le Maire Calls on U.S. to Back Global Digital Tax Plan
French Finance Minister Bruno Le Maire urged the U.S. to support a global overhaul of how the digital economy is taxed.
Posted on
States Should Conform To GILTI, Part 3
By Darien Shanske and David Gamage
This essay argues that the states should conform to the post-2017 federal tax law's provision for Global Intangible Low-Taxed Income (or "GILTI"). This essay is directed at state legislators and their staffs and presents the argument as succinctly as possible. The authors' argument can be summarized in three sentences. First, states should conform to GILTI because there is significant evidence that profit shifting is substantially eroding their corporate tax bases. Second, GILTI is a tool for identifying shifted profits. Third, there are many legally and analytically soundways to apportion GILTI income to a state. The authors also ÔøΩ briefly ÔøΩ counter the standard objections to state conformitywith GILTI.
Posted on
INSIGHT: Fiat State Aid Case - Impact on Luxembourg
The General Court of the EU has upheld the decision of the European Commission in the Fiat case, confirming that a tax ruling by the Luxembourg tax authorities conferred an advantagewhich constituted illegal state aid. Oliver R. Hoor and Keith O'Donnell of ATOZ Tax Advisers (Taxand Luxembourg) discuss the Court's decision andwhat itwill mean for Luxembourg going forward.
Posted on
U.S. Sanctions Over Digital Tax Would Make No Sense: Le Maire
French Finance Minister Bruno Le Maire says itwould be "incomprehensible" for the U.S. to sanction France for the introduction of a tax on digital revenue.
Posted on
U.S. Minimum Tax Should Be OK in Global Plan, Businesses Say
Companies are making the case they shouldn't face new rules and standards to complywith a global minimum tax plan.
Posted on
Treasury Aims Tax Fix to Keep $40 Billion R&D Spending in U.S.
The Treasury Department offered some relief to companies that lost foreign tax credits after investing in research and development operations in the U.S.
Posted on
Mexico May Speed Up Tax Overhaul If 2020 Revenue Disappoints
Mexican President Andres Manuel Lopez Obrador's administration may speed up plans for a tax overhaul to generate more revenue if 2020 budget assumptions turn out to be overly optimistic, a top official said.
Posted on
EU to Push for Tech Tax If Global Effort Fails, Vestager Says
The European Unionwill still pursue a digital tax even if a global push at the OECD fails, the EU's new digital czar told Bloomberg TV.
Posted on
Japan's Retail Sales Plunge After Sales Tax Hike, Typhoon
Japanese retail sales plunged in October after a sales tax hike and a super-typhoon kept shoppers at home, a factor the government is likely to consider as it mulls the size of a spending package to support growth.
Posted on
Ireland Dangerously Reliant on Company Taxes, Watchdog Says
Ireland is too reliant on corporation tax from a small number of international operations to fund spending, the state's fiscalwatchdogwarned.
Posted on
U.S. Proposes Duties on $2.4 Billion of French Goods Over Tech Tax
The U.S. proposed tariffs on roughly $2.4 billion in French products, in response to a tax on digital revenues that hits large American tech companies including Google, Apple Inc., Facebook Inc. and Amazon.com Inc
Posted on
How 'Digital Tax' Plans in Europe Hit U.S. Tech: QuickTake
Big internet companies have long been the target of complaints that they don't pay enough in taxes. Fed up, France imposed a 3% levy on the digital revenue of companies that make their sales primarily in cyberspace, such as Facebook Inc. and Alphabet Inc.'s Google. Other countries also are targeting companies, most ofwhich are American, that have multinational earnings that often escape the taxman's grip. The U.S. isn't taking this sitting down.
Posted on
Designing and Implementing a Destination-Based Corporate Tax
By Michael P. Devereux and Rita de la Feria
The authors argue that the current international tax system based upon the principles of source and residence is no longer suited to a globalisedworld economy, and the fundamentals of the international tax system need to be re-examined. They propose an R+F based cash-flow tax based on the principle of destination as a suitable alternative to taxing corporations in an international setting. The paper's aim is to discuss the legal and practical issueswhichwould arise in the implementation of such a tax, namely how a destination-based tax could be effectively designed and implemented. For this purpose the authors draw on experienceswith designing VAT systemsworldwide. It is proposed that the destination principle should be implemented through use of the customers' location as the main legal proxy.
Posted on
How Could the United States Implement a Global Tax Deal?
Mindy Herzfeld considerswhat steps the United Stateswould need to take for the OECD's pillar 1 proposals to becomeworkable for theIRS, aswell as for other tax authoritieswhen applied to U.S. taxpayers.
Posted on
Economic Analysis: How Much New Taxable Profit for Market Countries
In economic analysis, Martin A. Sullivan examines the OECD's attempt to rewire the international source rules so that more taxable profitsare allocated to marketjurisdictions than currently allowed under the arm's-length rules.
Posted on
France Endorses OECD Pillar 1 Global Tax Overhaul
France strongly supports the OECD pillar 1 proposal for allocating more taxing rights to market countries and suggests a 12.5 percent ratefor global minimumtaxation under pillar 2, according to a top official.
Posted on
UK Labour Would Raise Corp. Tax, Scrap Arm's-Length Pricing
The U.K. Labour Party pledged Thursday to return the corporation tax rate to 26% by 2022 and abandon the arm's-length standard ÔøΩ the traditional international approach for pricing transactions between related companies ÔøΩ if itwins next month's general election.
Posted on
Businesses Urge 'One-Stop Shop' For New OECD Tax System
Representatives from business groups pressed the Organization for Economic Cooperation and Development on Thursday to simplify its proposed new international tax system by using the tax administrationswhere large companies are headquartered as a "one-stop shop" for payment.
Posted on
Turkey's DST creates worry and double taxation issues
By Mattias Cruz Cano
The growing number of countries introducing a digital services tax (DST) could lead to "taxwars" rates, trade sanctions and disputes,warned senior tax professionals debating the issue.
Posted on
Amazon pushes for industry exemptions under pillar one proposals
Amazon is pressing the OECD to change the scope of the unified approach to apply to all businesseswith explicit exemptions for specific sectors.
Posted on
Amazon: OECD should adopt VAT principles to simplify digital tax plan
Amazon has suggested the OECD should adopt existing VAT principles to simplify the compliance and administration of its digital tax proposals under pillar one. It believes VAT rules on customer location could help, butwarns that privacy laws and VPNs mean it can only be part of the solution.
Posted on
Retail banking argues for exclusion from pillar one
The retail banking sectorwants to be exempted from the pillar one proposals under the OECD's digital tax plan because of existing, heavy financial regulations and possible mismatcheswith OECD policy considerations under pillar one.
Posted on
Navigating the EU-OECD Harmful Tax Competition Jungle
In this article, the author tracks the development of the EU and OECD actions to combat harmful tax competition and assesses the current state of play.
Posted on
A Unified Approach to International Tax Consensus
In this article, the author considers the OECD's "unified approach" proposal on the tax challenges of the digital economy, and questionswhether it represents a true international consensus.
Posted on
Up to 15 Multinationals Leave Philippines;Tax Reform Law Cited
The head of a Philippine business association said a tax reform program might be one of the reasonswhy 10 to 15 multinational companies' regional operating headquarters have pulled out of the country.