Int'l Tax News

In this article, the author considers the upcoming elections for the European Parliament and their potential impact on EU tax policy.

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.

Carrie Brandon Elliot describes how the proposed regs related to section 163(j) seek to help taxpayers avoid mismatches and double-counting.

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.

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).

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.

In this article, the author discusses the extensive global input received in response to the OECD's recent consultation document on the digital economy.

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.

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.

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.

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."

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.

The IRS has started applying data analytics to streamline its compliancework in connectionwith large, complex corporate taxpayers.

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.

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.

Ottawa plans to close the gap created by the repeal of Alberta's provincial carbon tax by implementing a replacement.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

Robert Goulder rethinks his initial opposition to a BEPS-influencedwithholding tax, as proposed by professors Yariv Brauner and Andrés Báez.

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.

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.

City leaders here are proposing to more than triple a tax on stock compensation in a bid to use revenue from awave of public offerings by tech companies to address concerns about growingwealth disparity. The so-called IPO taxwould raise the levy on corporations for stock-based compensation to 1.5% from the current rate of 0.38%. Thatwould restore the rate to its level in 2011when the city, pulling out of recession, cut it as part of a change in its tax structure intended to keep companies from leaving.

India's equalization levy on digital advertising revenuewill be repealed if countries settle on a new international tax framework for the digital economy, according to an Indian revenue official.

The administrability of rules on taxing the digital economywill be key to reaching international consensus on a long-term solution by the 2020 deadline, said Carol Doran Klein of the U.S. Council for International Business.

To protect its reputation, Ireland should continue to proactively participate in multilateral efforts to reform the international corporate tax rules, particularly the ongoing debate on taxing the digital economy, the IMF said.

U.S. Treasury officials have been engaged in "vigorous diplomacy" to dissuade countries from enacting unilateral measures ÔøΩ especially digital services taxes ÔøΩwhile countries are in the middle of negotiations on a global consensus-based solution.

Mindy Herzfeld questions the utility of the U.N. tax committee's efforts to provide its own solutions for taxing the digital economy, given that its membership is less exclusive than that of the OECD inclusive framework and its members act in individual, not representative, capacities.

Bavaria's Christian Social Union (CSU) has come out against a carbon tax as part of a German carbon pricing scheme, saying it prefers a reduction in energy taxes to spur environmental change.

A Swiss referendum on a tax reform package thatwould abolish cantonal tax regimes that the European Commission says favor multinationals over domestic companies is expected to pass May 18, according to a recent poll.

Ireland reported an 8 percent bump in net exchequer receipts for 2018, partly thanks to a double-digit increase in corporate tax receipts paid mostly by large multinationals, according to the Irish tax authority's latest results.

As governments continue debatingways to tax the digital economy, a top Google executive reiterated calls for simpler corporate tax rules, pledging that his companywill follow the new rules ÔøΩwhatever they may be.