Int'l Tax News

In response to the OECD's digital taxation consultation, online platform providers including Uber and Spotify expressed fear of being singled out and subjected to stiffer treatment than conventional businesses.

A cross-party committee of UK politicians has said the Big 4 accounting firms should be broken up, justweeks before the Competition and Markets Authority (CMA) is due to publish the results of its review into UK audit practices.

This paper is a draft chapter of a forthcoming book on the taxation of international business profit by the authors of this paper, to be published by Oxford University Press. The bookwill study two proposals for reform in depth: a destination based cash flow tax and a residual profit allocation.This paper focuses on the residual profit allocation by income proposal in detail.

Proposed rules for a 2017 tax law provision aimed at stopping U.S. multinationals from shifting profits offshorewould create a significant tax burden for natural gas and oil companies and other industries, group representatives said during an IRS hearing.

Companieswould have to provide more details about income taxes they pay under a proposal by U.S. accounting rulemakers. The Financial Accounting Standards Board said its March 25 proposal is intended to help investors and analysts understand a business's tax liabilities aswell as international tax exposureÔøΩa hot topic as more U.S. companies move operations and investments overseas. Under FASB's proposal, businesses must break down their income tax expenses or benefits, aswell as cash tax paid to domestic, foreign, and state governments.

A senior Dutch government official has called on countries to follow the Netherlands' lead and impose awithholding tax on royalty and interest payments to companies operating in low-tax jurisdictions and tax havens.

Brussels on Tuesday ruled that the UK gave illegal tax breaks to some multinational companies and ordered Britain to recoup lost revenues.

Cargill Inc.'s recent victory in a customs court case sets an important precedent for Brazil's exporters, shielding them from potentially huge tax fines. Brazil's revenue service appeals court, in a unanimous decision, upheld the legality of Cargill's export processes. The court rejected the revenue service's $2.6 billion fine, that equaled the total of the company's exports for 2013. The ruling is an important victory for exporters because "it recognizes that the mere existence of a company abroad for business operations, even in locations considered tax havens, does not render the operations unacceptable," said Fabio Pallaretti Calcini of the law firm Brasil Salomao and Matthes.

Denmark's parliament has given its final go-ahead to a landmark agreement thatwill see Airbnb Inc. share information on rental incomewith the local tax authorities. The agreement is due to come into force on July 1,with the information-sharing process due be automatized from 2021.

The Treasury Departmentwill refine guidelines that tell taxpayers how to show they qualify for a 2017 tax law perk for exporters, a Treasury official said.

The OECD haswarned that failure to reach a global agreement on how to tax the digital economy could lead to "international tax chaos."

A group of 15 Republicans on the Houseways and Means Committee urged thewhite House to "use all appropriate tools," potentially including trade responses, in response to taxes France and other countries are proposing for digital companies.

India is processing intercompany pricing pacts involving the U.S. and other countries at a faster clip than ever before, churning out 52 pacts in the year ended March 31, tax authorities said. Of the 52 deals India inked in 2018-19, 11were bilateral advance pricing agreements,which involve foreign tax departments aswell as companies, India's Central Board of Direct Taxes said.

The United Nations has issued a report, "Financing for Sustainable Development,"which calls for an overhaul to national and international financial systems in the face of inadequate digital tax rules and revenue.

Barbados Minister of Finance Ryan Straughn on March 20 presented to Parliament the draft 2019 budget,which proposes several new tax rules and amendments.

The imposition of additional taxes by European countries on U.S. technology giants could be metwith retaliatory measures on trade, a House Republican taxwriter iswarning.

The IRSwill likely seek to clarify a provision of the foreign-derived intangible income regs that establishes foreign use of intangible property used in manufacturing based on the location of the end-user.

The Austrian government is pushing a package of proposals to tax the digital economy comprising a 5 percent digital advertising tax and tax compliance measures targeting online booking and retail platforms.

France's digital services tax proposal has been amended to prevent double taxation and improve the transition to a global solution on digital taxation.

The Federal Court of Australia has held that two limited partnerships are taxable as companies on their Australian-source income and cannot claim treaty benefits as U.S. residents, setting aside a controversial earlier decision.

The EUwill ask the G-20 to give "the highest priority" to finding global solutions to the taxation of the digital economy.

The OECD recently published guidelines for countries thatwant online marketplaces like Amazon and eBay to assistwith VAT and goods and services tax collection, and stakeholders ÔøΩ including business ÔøΩ are giving them a standing ovation.

Australia's recent decision to not pursue a digital services tax has led to speculation that a similar levy under consideration by New Zealand might never come to fruition.

German Finance Minister Olaf Scholzwill urge financial leaders nextweek to strive for a minimum level of corporate taxation globally and increase debt transparency in developing countries, a senior German government official said on Friday.

With parliamentary elections looming, Australia's center-right government on April 2 presented a budget package calling for tax cuts for low- and middle-income earners and additional tax breaks for small and medium-size businesses.

An exemption from U.K. controlled foreign company rules for intragroup interest on debt funded by non-U.K. sources partially grants selective tax treatment to some multinationals and thus constitutes state aid, the European Commission said.

France is not specifically targeting U.S. internet giantswith a planned tax on digital service companies, its finance minister said in an interview, pushing back against pressure fromwashington to drop the levy.

In this article, the authors discuss the new Italian tax on digital services.

A Pennsylvania Democrat on Thursday reintroduced federal legislation thatwould make energy storage technologies fully eligible for the federal investment tax credit and joined scores of colleagues in calling for an extension of the ITC and other renewable energy credits that are currently scheduled to phase out.

Media-related businesses are united in their desire to 'level the playing field' on taxing traditional and digital companies, but they do not all agree on the bestway forward.

Tax directors are backing an independent standard-setting body, the Global Reporting Initiative (GRI), to introduce aworldwide standard to tax reporting and public disclosures, but manyworry that the standardwill clashwith CbCR.

The Australian Taxation Office is reviewing arrangements inwhich a multientity groupwith a large capital gain transfers the asset to an entitywith significant intragroup debt before selling the entity to a third party.

The European Commission has not yet determinedwhether itwill challenge a court decision overruling its finding that Belgium's excess profit tax schemewas illegal state aid, according to EU Competition Commissioner Margrethe Vestager.

The outcome of the OECD's ongoingwork on a global minimum tax regime may prompt the United States to rethink some recently enacted international tax rules.

In this article, the authors analyze 11 issues that the proposed U.S. base erosion and antiabuse tax regulations raise for the international banking industry.

The final Treasury regulations on global intangible low-taxed incomewill improve on the proposed regulations by adding clarity on key issues, including the scope of the proposed antiabuse rules.

Two companies have appealed a decision by the EU General Court that Spain's goodwill amortization scheme provided a selective advantage to foreign companies in violation of state aid rules.

A U.K. court has held that domestic legislation imposing immediate corporate tax liability for capital gains on intragroup stock transfers is a disproportionate measure that violates the EU right to freedom of establishment.

Carrie Brandon Elliot reviews several of the latest blockchain projects and how they affect the economy, illustrating how decentralization, anonymity, and massive transaction volumes may render the OECD's two pillars obsolete in the near future.

Mindy Herzfeld describes proposals to revise global tax rules to allocate a greater share of multinational companies' profits to market jurisdictions, including several presented during the OECD's recent consultation on the tax challenges of digitization.

Lee A. Sheppard examines the proposed regs to implement the hybrid mismatch rules thatwere included in the Tax Cuts and Jobs Act.

Stephenwang is counting the costs of President Donald Trump's tradewar. He had to put down 12 times more cash as a guarantee to U.S. customs that hewould pay the bill for tariffs on the Chinese-made pumps, valves and motors he imports. The cost of the guarantee - a U.S. customs bond - has shot up, an additional hit to importers already facing steep customs bills adding up to tens of billions of dollars for tariffs imposed by the Trump administration on incoming Chinese goods, aswell as steel and aluminum imports.

Stephenwang is counting the costs of President Donald Trump's tradewar. He had to put down 12 times more cash as a guarantee to U.S. customs that hewould pay the bill for tariffs on the Chinese-made pumps, valves and motors he imports. The cost of the guarantee - a U.S. customs bond - has shot up, an additional hit to importers already facing steep customs bills adding up to tens of billions of dollars for tariffs imposed by the Trump administration on incoming Chinese goods, aswell as steel and aluminum imports.

The U.S. economy slowed more than initially thought in the fourth quarter, keeping growth in 2018 below the Trump administration's 3 percent target, and corporate profits fell by the most in a year after a one-off boost from lower taxes.

As the international push to discourage tax avoidance and secrecywages on, many countries that formerly marketed themselves as tax havens are now looking to become hubs of blockchain, the online ledger system used to record cryptocurrencies ÔøΩ and much more.

While the European Union and Britainwrestle over the "Irish backstop" issue in their stalled Brexit agreement, a similar problem is taxing another island at the other end of the continent - Cyprus.

U.S. companies more than quadrupled the amount of foreign earnings they sent home in 2018 following enactment of a tax-law overhaul in late 2017, though the size of so-called repatriations declined after an initial spike.

PwC submitted, on behalf of a group of companies, a comment letter on February 19, 2019,which addresses an issue arising from the interaction of Section 267(a)(3)(B)with the TCJArepeal ofSection 958(b)(4).

British businesses havewelcomed confirmation from the UK Government that Making Tax Digitalwill not be rolled out to other taxes and more businesses in 2020.