Posted on
EU Money Laundering Blacklist to Get a Reboot, Commissioner Says
A revamped money laundering blacklistwill be submitted to the EU Council in October, EU Justice Commissioner Věra Jourová told Tax Notes.
Posted on
OECD Digital Work Expected to Yield Small Shift in Taxing Rights
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.
Posted on
Tax Transparency in Fits and Starts
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.
Posted on
Consolidated Groups Still Facing Hybrid and DCL Problems
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.
Posted on
The Limits of Friendlier Tax Administration, Part 2
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.
Posted on
Canada Seeks International Consensus on Digital Taxation
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.
Posted on
Mexican Government to Propose a Digital Services Tax in 2020
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.
Posted on
U.N. Transfer Pricing Manual Draft Updates Seek OECD Alignment
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.
Posted on
Tax Committee Leaders Caution Against Digital Services Taxes
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.
Posted on
H.R. 2210 Would Repeal FIRPTA Provisions
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.
Posted on
EU Energy Union Seconds Switch to Qualified Majority Voting
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.
Posted on
Top Taxwriters Urge Collaboration on Digital Tax Problem
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.
Posted on
Minnesota Provision Creates GILTI Trigger for Combined Reporting
Minnesota House lawmakers have introduced a bill thatwould include foreign corporations that generate global intangible low-taxed income in the corporate unitary group.
Posted on
U.S. Treasury Criticism of EU Anti-Money Laundering Blacklist Shows Cracks in Financial Enforcement
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.
Posted on
BEPS Aftermath: Mechanisms to Curtail Treaty Shopping and Abuse
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.
Posted on
Germany to mull carbon tax as part of national climate pact
Germany's environment minister says the governmentwill discuss introducing a carbon tax as part of its national plan to curb climate change.
Posted on
Corporations are cheating the global tax system. World leaders can't afford to ignore it
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.
Posted on
Czech Republic Implements ATAD Measures
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.
Posted on
European Commission Speaks Out Against Tax Unanimity
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.
Posted on
France Must Cut Taxes Quickly to Quell Public Anger, PM Says
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.
Posted on
Swiss Corporate Tax Reform- Considerations for Multinationals
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.
Posted on
Treasury Pressed to Fix Tax Mistake That May Push R&D Offshore
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.
Posted on
Tax Treatment of Stock Payments High on Treasury's Agenda
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.
Posted on
Slicing the Shadow: OECD Consultation Highlights Profit Allocation Difficulties
Jeff VanderWolk of Squire Patton Boggs querieswhether the OECD needs to revise profit allocation rules to address digitalization.
Posted on
Germany, Netherlands Team Up to Push for Minimum Corporate Tax
Germany, Netherlands plan towork together to establish "minimum tax standard" to counter tax havens, according to joint statement supplied by Germany's Finance Ministry.
Posted on
Brace Yourself, Corporate America: Taxes Are About to Go Up
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.
Posted on
France Must Stop Creating Taxes, Budget Minister Says
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.
Posted on
Digital Services- Tax Implications (Part 4)
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.
Posted on
Rettig Doubles Down on Transfer Pricing Cases
IRS Commissioner Charles Rettig reiterated his intent to crack down on the use of complex offshore tax evasion techniques involving intellectual property.
Posted on
Euro-Wide Digital Tax Solution Could Spur Global Consensus
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.
Posted on
Netherlands Ratifies OECD's Super Tax Treaty
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.
Posted on
U.S. Digital Tax Plan Complex for Developing Countries: Official
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.
Posted on
European Ministers Urge Action on Corporate Tax Reform
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.
Posted on
Companies Must Prove Foreign Use or Face Losing Export Deduction
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.
Posted on
OECD Digital Tax Solution Must Weigh Simplicity and Precision
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.
Posted on
EU Aims to Unify Members on Digital Tax, Fall in Line With OECD
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.
Posted on
Snap AV: tax cuts = share buy backs
A new chart from Deutsche Bank's economicswizard Torsten Slok shows the effect of Trump's corporate tax cuts.
Posted on
Russia- Challenges of the Google Tax
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.
Posted on
France Wants Tax Cuts: That's the Message From Macron Town Halls
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."
Posted on
Macron Aims to Force 'Tax Justice' on Facebook, Google and Apple
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.
Posted on
EU's Vestager: Best Thing Is Global Solution on Digital Tax
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.
Posted on
French Digital Tax Bill Could Offer Reprieve for Ad Exchanges
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.
Posted on
Cross-Border Sales: Where's the Market Jurisdiction?
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.
Posted on
Shell to Cut Ties With Industry Group Over Carbon Pricing Spat
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.
Posted on
Corruption Reform Could Lift Tax Intake by $1 Trillion, IMF Says
If governmentswere to take proven steps to attack corruption, global tax revenueswould increase by approximately $1 trillion, the IMF said April 4.
Posted on
Major Cross-Border M&A Down Since TCJA
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.
Posted on
France Sticking With Digital Services Tax Despite U.S. Warnings
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.
Posted on
Consolidated Groups Seek Deductions Under Proposed FDII and GILTI Regs
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.
Posted on
Pompeo Urges France Not to Approve Digital Services Tax
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.
Posted on
JPMorgan head says Trump tax law added $3.7B to its profit
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.