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Recent Changes to South Korea's Corporate Tax Laws
In this article, the authors discuss recent changes to South Korea's tax laws, including several amendments that took effect January 1,with a focus on changes that may affect foreign companies doing business in Korea.
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U.K. to Seek Brexit Customs Backstop Alternatives by 2020
The U.K. governmentwill seek to find alternative options to a backstop plan to avoid a hard customs border between Northern Ireland and Ireland by December 2020 as part of a 10-point "new Brexit deal."
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Australia government says it won't break tax cut pledge
Australia's newly reelected government said Tuesday that its promise to slash income taxes might be delivered late butwould not be broken as it seeks to stimulate consumer spending, revive a flagging economy and repair relationswith China, its most important trading partner.
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Senators Announce Bills to Discourage Offshoring, Tax Haven Use
The Removing Incentives for Outsourcing Actwould institute a country-by-country minimum tax for controlled foreign corporations,while the Disclosure of Tax Havens and Offshoring Actwould expand CFC financial reporting, Sens. Chris Van Hollen, D-Md., Amy Klobuchar, D-Minn., and Tammy Duckworth, D-Ill., said in a May 22 release announcing the bills.
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German Government Approves R&D Incentive Bill
With the German government's approval of a bill thatwould offer a 25 percent allowance for qualifying research expenses, Germany has taken another step toward enacting its first tax incentive for research and development.
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U.K. Think Tank Proposes 'Simple' Turnover Tax
Smaller U.K. companies should be able to opt for a levy on turnover to replace corporation tax, business rates, VAT, and the employer's National Insurance contribution, according to the Centre for Policy Studies (CPS).
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U.S. Tax Review
In this article, the authors discuss the annual IRS report on advance pricing agreements, the IRS's new unit on competent authority, comments from the Silicon Valley Tax Directors Group on the base erosion and antiabuse tax, and the New York State Bar Association's comments on the proposed partnership nonrecognition transaction regulations and antiabuse rules.
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OECD Weighing Extensive Input on Digital Economy Tax Proposals
In this article, the author discusses the extensive global input received in response to the OECD's recent consultation document on the digital economy.
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EU Reports Promising Talks With U.S. on Taxing Digital Economy
A global solution is necessary for the fair taxation of multinationals in the digital economy, and the EU is having positive discussionswith the United States on the subject, the EU's tax chief said.
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EU to Assess Impact of OCED's Digital Tax Plans
EU member stateswillwork together to assess the impact of OECD plans for taxing the digital economy, Romanian Finance Minister Eugen Teodorovici told reporters after a meeting of EU finance ministers in Brussels May 17.
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EU Elections and EU Taxation
In this article, the author considers the upcoming elections for the European Parliament and their potential impact on EU tax policy.
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Proposed Regs Target Old CFC Attribution Issues, Avoid New Ones
Treasury and the IRS have proposed regulations restricting the scope of downward attribution of stock in controlled foreign corporationswithout addressing one of the Tax Cuts and Jobs Act's controversial and seemingly unintended consequences.
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New Regs Ease Double Counting and Mismatches
Carrie Brandon Elliot describes how the proposed regs related to section 163(j) seek to help taxpayers avoid mismatches and double-counting.
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High Line on the Hybrid Rules
Lee Sheppard looks at the state ofwithholding on payments to hybrid entities and payments on hybrid instruments after the recent release of guidance by the U.S. Treasury.
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U.K. Think-Tank Proposes 'Simple' Turnover Tax
Smaller U.K. companies should be able to opt for a levy on turnover to replace corporation tax, business rates, VAT, and the employer's National Insurance contribution, according to the Centre for Policy Studies (CPS).
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U.S. Tax Review (1)
In this article, the authors discuss the annual IRS report on advance pricing agreements, the IRS's new unit on competent authority, comments from the Silicon Valley Tax Directors Group on the base erosion and antiabuse tax, and the New York State Bar Association's comments on the proposed partnership nonrecognition transaction regulations and antiabuse rules.
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OECD Weighing Extensive Input on Digital Economy Tax Proposals (1)
In this article, the author discusses the extensive global input received in response to the OECD's recent consultation document on the digital economy.
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Companies examining long-term benefits of Swiss tax
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CNBC analysis: Trump tariffs among largest tax hikes in decades
President Trump's tariffs have amounted to one of the largest tax increase in recent decades, according to CNBC. Accord to the network's analysis, the Treasury has collected $72 billion in import taxes Trump has imposed as part of his trade policy.
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U.S. Economy Lost Some Steam at Start of Second Quarter
The U.S. economy got off to a sluggish start in the second quarter,with both consumers and manufacturers pulling back in April amid trade tensions, a global slowdown andwaning effects of the 2017 tax cuts.
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Reorganisations slow amid vague indirect transfer tax regimes
Uncertainty over how to tax offshore indirect transfers and delay to establishing an international framework for taxing such transfers is leading to a slowdown in corporate reorganizations.
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OECD Deal On Corp. Tax Needed For EU Effort, Official Says
Itwould be more effective for there to be a deal among members of the Organization for Economic Cooperation and Development on a minimum corporate tax before the European Union tries to establish one, a European Commission official said Thursday.
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German Finance Minister Expects OECD Deal on Digital Tax in 2020
German Finance Minister Olaf Scholz said on Friday he expected the Organisation for Economic Cooperation and Development (OECD)will agree a minimum level of taxation for digital companies such as Amazon, Google and Facebook by mid-2020. He also said he expected progress by the third quarter of 2019 on introducing a financial transaction tax in at least nine EU countries.
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Why a Tax the U.S. Hasn't Embraced Has Found Favor in Much of the World
You may not like paying taxes, but your burdenwill be even higher if others don't pay their fair share. That, in a nutshell, goes a longway toward explainingwhy a value-added tax, or VAT, is used by just about every major country in theworld except the United States.
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Buttigieg climate plan includes carbon tax
Presidential hopeful Pete Buttigieg (D)wants to tax carbon emissions as part of his climate action agenda. The South Bend, Ind., mayor listed pricing carbon from polluters as one of his campaign policy initiatives on hiswebsite. Speaking to theSkimm on Thursday, he said the plan to tax carbon polluters and distribute the profits as dividends back to Americanswould allow the public to "actually see more money in our pockets."
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EU Commission Presidency Hopefuls Agree on Carbon, Digital Taxes
In a televised debate, six candidates for the European Commission presidency found common ground on opposing aggressive tax avoidance, using carbon taxes to combat climate change, and taxing the digital economy.
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IRS Rolls Out Large Corporate Compliance Program
The IRS has started applying data analytics to streamline its compliancework in connectionwith large, complex corporate taxpayers.
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ABA Tax Section Suggests Further Guidance on BEAT Regs
Eric Solomon of the American Bar Association Section of Taxation has submitted comments on proposed base erosion and antiabuse tax regulations (REG-104259-18), identifying provisions that it suggests should be reconsidered and other areas that need further clarification.
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States Should Not Include GILTI in Their Tax Base, Panelists Say
Global intangible low-taxed income is more than tax avoidance income and should not be taxed at the state level, according to some tax experts.
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Ottawa to Respond to Alberta's Carbon Tax Repeal With New Levy
Ottawa plans to close the gap created by the repeal of Alberta's provincial carbon tax by implementing a replacement.
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Luxembourg's New CFC Rules
In this article, the author analyzes the scope and mechanics of Luxembourg's new controlled foreign company rules and considers problems such as overlapwith transfer pricing rules and the risk of double taxation.
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Trade Council Suggests Changes to FDII Regs
The National Foreign Trade Council has commented on proposed foreign-derived intangible income regulations (REG-104464-18), suggesting changes regarding the documentation requirements, the foreign derived ratio, the ordering rules, the treatment of some loss transactions, foreign branch income, and some other issues.
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What the Swiss Vote on Taxes Means for Multinationals
Switzerland is trying to hold on to its appeal as an attractive place for companies. In a May 19 referendum, voterswill decidewhether to accept or reject a new corporate tax regime to replace the special tax breaks that multinational companies now enjoy.
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EU to Remove UK, Dutch Overseas Territories From Tax Haven Blacklist
European Union finance ministers are set to remove thisweek the British overseas territory of Bermuda, the Dutch Caribbean island of Aruba and Barbados from the bloc's blacklist of tax havens, an EU official said on Monday.
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Tax treaty 'pool rules' needed to ensure no double-taxation horseplay
If you've ever been to a public swimming pool, you're familiarwith the "pool rules" posted near thewater: No diving, no running and no horseplay. These rules exist to keep everyone safe. In the sameway, international tax treaties set ground rules among countries ÔøΩ protecting taxpayers from double taxation and giving companies confidence to invest. But for nearly a decade, the Senate has been blocked from approving any of these routine and vitally important treaties.
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Taxpayers caught up in CFC state aid ruling expect UK to appeal
Companies such as the Daily Mail Group, Diageo and the London Stock Exchange are expecting the UK to appeal the EU's state aid decision against the country's CFC group financing regulation, but there is very little time to file a challenge.
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E.ON Chief Says Germany Should Charge CO2 Tax, but Spare Consumers
E.ON Chief Executive Johannes Teyssen on Tuesday proposed a carbon dioxide tax of 35 euros ($39.34) a tonne thatwouldwiden the burden-sharing for climate protection to big emitters such as transport and heat provision.
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Taxpayers say India's proposed move to fractional apportionment would intensify disputes
The consultation period for feedback on India's proposed changes to its profit-attribution rules has not yet ended, but the debate around the potential costs and benefits of any change is already hotting up.
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Pension Investment Board Looks for Exception in BEAT Regs
The Public Sector Pension Investment Board, following up on prior comments, has asked that the base erosion antiabuse tax regulations provide an exception to the BEAT aggregation rule so that organizations that lack private shareholderswill be treated as other than corporations for purposes of applying the code's attribution and control tests.
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European Greens Group Unveils Tax Justice Agenda
A European Parliament groupwill be advocating for reforms set forth in a blueprint that takes aim at several tax policies and practices favoring large companies and high-wealth individuals.
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Belgian Political Parties at Odds Over Taxation of Capital
While the tax burden onworkers remains high in Belgium, the country's political parties have been unable to reach a consensus on how to shift it to capital.
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IMF Warns Czech Republic on Unilateral Taxes on Foreign Firms
Targeting extra taxes on specific sectors such as foreign companies may be attractive but could be economically damaging, the IMF told the Czech Republic in an obliquewarning against its plans for a digital tax.
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For New Digital Economy Tax Regimes, Haste May Threaten Quality
Strong public pressure for immediate action ÔøΩ particularly in Europe ÔøΩ to tax large digital companieswith significant local revenue has prompted the spread of unilateral tax measures that are politically popular but technically flawed.
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Mauritius Issues Notice for Nonoperating Companies
Mauritius companies that have not yet started, or have ceased, operations and have not derived any income during a fiscal year must submit a declarationwithin three months from the end of that fiscal year.
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OECD-Brazil Transfer Pricing Project Inching Toward Announcement
The OECD is eyeing July to present key findings and next steps following the conclusion of a project examining Brazil's potential to align the country's transfer pricing regimewith global standards.
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TCJA May Lead to Luxembourg Tax Revenue Fall, IMF Says
The U.S. Tax Cuts and Jobs Act could lead to long-term tax revenue losses of 7 percent of corporate income tax revenues in Luxembourg because it mayweaken multinationals' incentives to locate assets there, according to the IMF.
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Final U.S. Branch Currency Regs Change Course on Partnerships
The decision towithdraw the temporary branch currency regulations on aggregate partnershipswhile finalizing only antiabuse rules suggests Treasury and the IRS have yet to decide on the right approach to a difficult issue.
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BEPS and Withholding: Unlikely Bedfellows
Robert Goulder rethinks his initial opposition to a BEPS-influencedwithholding tax, as proposed by professors Yariv Brauner and Andrés Báez.
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Treasury, IRS Open to Suggestions on PTI Simplification
While IRS and Treasury Department officials share taxpayers' concerns regarding the complexity of the proposed regulations on previously taxed income, there are few obviousways to simplify an inherently complex area.
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US Companies Urge Senate To Approve Tax Treaties
In a letter published on April 29, 2019, the United States National Foreign Trade Council urged the Senate to approve several pending double tax avoidance treaties. The letter, signed by more than 85 US companies, highlights the important role of income tax treaties in fostering bilateral trade relations and protecting US taxpayers from double taxation.