Int'l Tax News

A revamped money laundering blacklistwill be submitted to the EU Council in October, EU Justice Commissioner Věra Jourová told Tax Notes.

A modest reallocation of taxing rights that is palatable to countries losing some tax revenues could be key to addressing the challenge of generating OECD consensus on new global tax rules.

Mindy Herzfeld describes recent proposals to make corporate tax data more transparent, including those by the Financial Accounting Standards Board and the Global Reporting Initiative.

In news analysis, Carrie Brandon Elliot reviews how the new hybrid proposed regulations solve some, but not all, of thewell-known problems related to dual consolidated losses.

In news analysis, Lee A. Sheppard discusses emerging trends in tax collection in developing economies and how these are causing difficulties for traditional organizations like the OECD and IMF.

Canadian Finance Minister Bill Morneau reiterated that Canada is awaiting the OECD's report concerning digital taxation and noted the importance of the United States' position to Canada's future decisions.

A recent statement by Deputy Finance Minister Arturo Herrera that the Mexican government intends to tax digital services has prompted concerns that pending legislation might be used to implement the plan.

The U.N. has released a package of draft updates to its transfer pricing manual for developing countries, including a new chapter on financial transactions and revised profit-split guidance consistentwith recent OECD updates.

In an April 10 release, the chairs and ranking minority members of the Houseways and Means and Senate Finance committees expressed support for OECD negotiations on the digital economy and said digital service taxes, even on an interim basis, can have negative effects on U.S. businesses, the economy, and diplomacy.

H.R. 2210, the Invest in America Act, introduced by Houseways and Means Committee member John B. Larson, D-Conn.,would repeal provisions of the Foreign Investment in Real Property Tax Act of 1980 concerning capital gains taxation of U.S. investments by foreigners, in addition to repealing other provisions to stimulate foreign investment in the United States.

The EU Energy Union said it supports the European Commission's proposal to move away from unanimity to qualified majority voting (QMV) on energy taxation.

Countries shouldn't enact unilateral digital services taxes but should insteadworkwith the international community to find a solution, U.S. lawmakers urged in a statement.

Minnesota House lawmakers have introduced a bill thatwould include foreign corporations that generate global intangible low-taxed income in the corporate unitary group.

In this article, the author discusses the process and rationale behind the EU's anti-money laundering blacklist and the U.S. Treasury's response.

In this article, the author examines OECD and U.S. approaches to counteract treaty shopping and abuse and provides a framework of topics that taxpayers might need to focus on to claim treaty benefits. He also explores the symbiotic relationship between U.S. tax treaty policy and the action plans released as part of the OECD's base erosion and profit-shifting project.

Germany's environment minister says the governmentwill discuss introducing a carbon tax as part of its national plan to curb climate change.

There is no gap in the architecture of globalization more serious than the failure of nations to prevent global companies andwealthy individuals from escaping taxation through tax havens, accounting devices and pressure to bring down business tax rates.

The Czech Republic has published corporate income tax amendments in connectionwith its implementation of the EU's anti-tax-avoidance directive (ATAD). Most of the new measures took effect April 1.

The European Commission rerouted an informal discussion on growth and taxation by the Economic and Financial Affairs Council April 6 to promote a shift toward qualified majority voting in tax matters. Three member states said they oppose the move.

The French public is exasperated over the country's high tax burden, so the government must respond quickly and decisively, France's prime minister said following the close of a national consultation initiated after violent protests.

The objective of the proposed Swiss corporate tax reform is to ensure that the Swiss corporate tax system is in linewith international minimal standards,which recognize as harmful the cantonal preferential tax regimes for holding, domicile and mixed companies. Accordingly, these privileged tax regimes need to be abolished by the cantons. The proposed new tax provisions are intended to achieve international acceptancewhile at the same time maintaining Switzerland's attraction for multinational enterprises.

The Treasury Department is being pressed by Republican lawmakers and business groups to correct a defect in a new tax on foreign earnings that has companies like biotech giant Amgen Inc. saying they may move their research and development operations offshore. They are asking Treasury to clarify how to properly allocate research and development expenses under the new rules,which are meant to ensure multinationals pay at least a minimum amount of tax on overseas profits earned in countrieswith lower tax rates than the U.S.

The treatment of stock payments under the new base erosion and anti-abuse tax is high on Treasury's list of outstanding items to tackle, an official said. The Treasury Department has received comments on pending issueswith the BEAT, includingwhether non-cash or property payments, including stock payments or the assumption of a liability, should be captured under the new tax.

Jeff VanderWolk of Squire Patton Boggs querieswhether the OECD needs to revise profit allocation rules to address digitalization.

Germany, Netherlands plan towork together to establish "minimum tax standard" to counter tax havens, according to joint statement supplied by Germany's Finance Ministry.

President Donald Trump's signature tax cuts are set to end starting 2021, and Corporate America must prepare for an increase in levies as it's unlikely Congresswill extend the stimulus, according to Morgan Stanley.

French Budget Minister Gerald Darmanin said March 29 that the state must stop creating new taxes and rather cut spending, in an interviewwith RMC radio.

The final part of this four-part Insight continues a review of the different forms of digital services tax introduced as interim measures in a number of jurisdictions until a global solution is reached.

IRS Commissioner Charles Rettig reiterated his intent to crack down on the use of complex offshore tax evasion techniques involving intellectual property.

A European-wide digital tax could have driven a global solution to the challenges of taxing the modern economy, said EU Competition Commissioner Margrethe Vestager.

The Netherlands officially ratified the OECD's multilateral "super tax treaty" designed to implement measures to prevent base erosion and profit-shifting in double-tax treaties March 29, joining 23 other jurisdictions.

The U.S. proposal to tax the digital economy could prove to be difficult to implement, especially for developing countries, an OECD official said. The complexity may put developing countries off from backing the U.S. proposal, according to Sophie Chatel, head of the Tax Treaty Unit at the OECD Center for Tax Policy and Administration.

European Union finance ministerswill make a push to include corporate tax reform at the top of the European Commission's agenda at a meeting in Bucharest.

U.S. exporterswill lose their ability to take a deduction on foreign-derived income if they're unable to prove to the IRS that the exportswere intended for foreign use. Companies should have "reason to know" that their goods and serviceswere meant for foreign persons and foreign use, and provide documentation to substantiate that claim if the goods find theirway back to U.S. soil.

Any solution to the digital taxation problemwill have to balance the desire for a simple solution against the need for precision, the OECDwarned. The Organization for Economic Cooperation and Development is grapplingwith the concepts as part of itswork to find solutions to taxing the digital economy, according to its senior officials.

The European Commissionwill try to unite countries on digital tax proposals being discussed at the OECD to ensure the plan alignswith the bloc's plans to reform corporate tax.

A new chart from Deutsche Bank's economicswizard Torsten Slok shows the effect of Trump's corporate tax cuts.

There have been significant changes to theway electronic services are taxed in Russia. Anton Nikiforov of Pepeliaev Group discusses the challenges that foreign companies face and how these challenges can be overcome.

The Frenchwant to pay less tax. Thatwas the clear message that emerged from a two-month "Great Debate" that saw voters present their grievances and suggest remedies to President Emmanuel Macron. "There's an exasperation about taxes," Prime Minister Edouard Philippe said in Paris April 8, as hewas presentedwith a study outlining the findings of the national debate. "The clear message is that taxes must fall and fall fast."

French lawmakerswill start debating April 8 a tax meant to force Internet giants like Amazon Inc. and Facebook Inc. to pay a 3 percent levy on digital turnover.

EU Competition Commissioner Margrethe Vestager says, "The best thing is a global solution, but ifwewant solutions in a reasonable time, then Europe must step forward," on France Inter, a radio channel part of Radio France.

France's National Assemblywill begin debate April 8 on a far-reaching bill thatwould impose a tax on revenue tech companies make from certain digital servicesÔøΩbut could exclude ad exchanges from the tax. The proposal to exclude such exchange companiesÔøΩthose that help advertisers place targeted ads onlineÔøΩwould address industry complaints that the legislationwould tax them twice on revenue they earn from certain types of digital advertising.

Jeff VanderWolk of Squire Patton Boggs discusses the feasibility of the OECD's proposal to allocate non-routine or residual income of a multinational business based on marketing intangibles.

Royal Dutch Shell PLC has announced that itwill be bowing out of a prominent U.S. industry association overwhat it views as a "material misalignment" on climate policy, including carbon pricing.

If governmentswere to take proven steps to attack corruption, global tax revenueswould increase by approximately $1 trillion, the IMF said April 4.

While the U.S. Tax Cuts and Jobs Act has created new incentives for dealmakers, trade tensions continue to pose a challenge to deal activityworldwide, and cross-border megadeals are at a historic low.

Francewon't drop its digital services tax despite the U.S. secretary of state'swarnings butwill keepworkingwith the United States to acceleratework on an OECD-level solution to tax the digital economy.

The Tax Cuts and Jobs Act's new section 250 provides domestic corporationswith deductions for foreign-derived intangible income and global intangible low-taxed income. Meanwhile, deemed dividends that are attributable to GILTI under section 78 are also deductible.

U.S. Secretary of State Mike Pompeo urged France in a meetingwith his French counterpart Jean-Yves Le Drian on Thursday not to approve a digital services tax, saying itwould hurt U.S. technology firms, the U.S. State Department said.

JPMorgan CEO Jamie Dimon lauded President Trump's tax cuts, saying the legislation passed in 2017 boosted the bank's net profit by $3.7 billion. "All things being equal (which they are not), the new lower tax rates added $3.7 billion to net income," Dimon said in JPMorgan's annual investor letter on Thursday.