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U.S. Consumption Tax of 5% Could Raise $3 Trillion Over Decade
Many countries, including members of the OECD, raise revenuewith a consumption tax levied on incremental increases in the value of goods and services as they move through the supply chain. These value-added taxes generate considerable income and are relatively efficient to administer.The Congressional Budget Office recently issued a report highlighting this policy option to possibly help reduce the U.S. budget deficit.
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Digital Services- Tax Implications (Part 2)
Part 2 of this two-part Insight looks at the different forms of digital services tax being introduced as interim measures in a number of jurisdictions until a global solution is reached.
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Dutch Lawmakers Urge Delay of Retroactive Tax Measure
Lawmakers are urging the Dutch government to delay the effective date of a tax measure thatwould hit thousands of the country's largest companies. Several lawmakers urged Dutch State Secretary for Finance Menno Snel on Feb. 6 to make the rules retroactive to Jan. 1, 2019, instead of the proposed Jan. 1, 2018. These are rules thatwould limit the deductibility of intragroup interest payments made by Dutch consolidated companies that file a single tax return.
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Companies Want Guidance on Tax Overhaul's Export Deduction
Companies arewaiting for IRS guidance to seewhether and how they can benefit from a new tax deduction designed to encourage exports under the foreign-derived intangible income provision.
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U.S. Tax Credits Not Certain for Foreign Digital Taxes
The Treasury Department may or may not give a credit to companies for payments they make under digital tax regimes of other countries said Lafayette G. "Chip" Harter, deputy assistant secretary of international tax affairs at U.S. Treasury.
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Merck, Honeywell Revise 2017 Tax Overhaul Charge Estimates
Merck & Co. Inc. and Honeywell International Inc. revised their estimates for 2017 tax overhaul expenses during their most recent quartersÔøΩa full year after enactment of the law.
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Digital Services-Tax Implications (Part 1)
Numerous tax jurisdictions have undertaken to ensure internet companies pay their share of tax: new regulations are being implemented, such as a digital services tax ("DST") in the EU, the equalization levy in India, and other similar taxes. Part 1 of this two-part Insight looks at the new digital business models and the challenges they pose to current international corporate tax regulation.
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Microsoft's Landmark Win in Tax Case Hinders Danish Tax Authority
Microsoft Corp.'swin in a landmark tax case at Denmark's Supreme Court may force the Danish tax authority to re-examine theway it goes after global companies.
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Developing Nations Seek 'Simplicity' in Global Tax: IMF Official
Simplicity is a main priority of developing countries in the ongoing global discussion about redrawing international tax rulesÔøΩmaking a solution such as formulary apportionment attractive said Ruud de Mooij, chief of the tax policy division at the International Monetary Fund's fiscal affairs unit.
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Chile Looks to Blockchain to Support Tax Collection
Chile is studying how to incorporate blockchain technology to improve its tax-collection powers as part of a broader move toward digital government. The government is preparing a conceptual model thatwould use blockchain to monitor payments received from banks and other private entities and then automatically inform the corresponding government service said Cristian Cespedes, head of information technology at the General Treasury of the Republic.
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Geneva Seeks Higher Tax Rate for Multinationals
Swiss-based multinationals like Cargill and Caterpillarwould have to pay higher taxes under a broad tax reform plan that, if approved in a popular referendum May 19,would become effective next year.
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Jair Bolsonaro faces congressional test for radical reforms
After the most turbulent start to a government in Brazil's recent history the country's congress gets down to business thisweekwith a controversial agenda, but alsowith a scandal to distract it. Jair Bolsonaro, the rightwing former army captainwho rose from political obscurity towin the presidency against a handful of establishment candidates, is hoping he has enough support in a traditionally fractious legislature to push through a radical slate of reforms. One of these reforms include simplifying the country's labyrinthine municipal, state and federal tax systems into single national rates of income and value added tax.
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Tax Law Fixes to Be Subject to 'Heavy Negotiation': Dem. Aide
House Democrats arewilling to considerways to fix errors in the Republican tax law, but any changes are likely subject to "heavy negotiation" between the two political parties, the Houseways and Means Committee's chief tax counsel Andrew Grossman said.
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Repatriation Tax 'Transfer Agreement' Deadline Postponed
The Jan. 31 deadline for transferring the chosen tax treatment of repatriated assetswill be postponed to 30 days after recently issued rules are published in the Federal RegisterÔøΩin "a couple days," a Treasury official said.
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IRS to Tighten Foreign Tax Anti-Abuse Rules Amid Comment Deluge
The IRS is taking another crack at proposed rules for preventing abuse of the 2017 tax overhaul's global intangible low-taxed income provision after hearing from tax professionals that the ruleswere too broad.
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OECD Lauds Efforts to Eliminate Harmful Tax Practices
Countries have changed how they tax multinational companies' income from intellectual property in order to combat harmful tax practices, according to an OECD's head of international cooperation and tax administration Achim Pross. His remarks came during a Jan. 29 OECDwebcast, following the organization's same-day release of its 2018 progress report on preferential tax regimes.
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Ireland Ratifies OECD's Super Tax Treaty
Ireland became the 19th jurisdiction to ratify the multilateral instrument, the OECD's ambitious super-tax treaty designed to crack down on corporate base erosion and profit-shifting.
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OECD Digital Tax Solution Will 'Revisit' Fundamental Principles
The OECD said itwill move beyond one of the bedrock principles of international taxation to tackle the problem of taxing corporations in a digital era.with many countries clamoring to collect more tax from multinational companies, especially tech giants, pressure is on the OECD towrite new tax rules that address those concernsÔøΩbut can still find common global agreementÔøΩby its 2020 deadline. Thatwill mean "going beyond" the arm's-length principle, the OECD said in a Jan. 29 statement.
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Australia's Fund Managers Push Lower Tax Rates to Lure Investors
Fund managers are pushing Australia to lowerwithholding tax rates and soften the rules for a proposed investment vehicle they hope could help the country attract foreign investment and become more competitive.
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Customs Valuation and Transfer Pricing- a China Perspective (Part 2)
Part 1 of this two-part series summarized the latest 2018 version of Guide to Customs Valuation and Transfer Pricing released by theworld Customs Organization. Part 2 comments on the trends and observations in the interaction between customs valuation and transfer pricing from a China perspective.
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Multinationals Still Feeling Pain Over U.S. Tax Calculations
Tax directors at Vivendi SA, GE's Baker Hughes, and Johnson & Johnson say they're still strugglingwith adjustment to the U.S. tax law, a year after passage of the tax overhaul.
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EU's Digital Tax Proposal Will Hurt Trade, U.S. Businesses Warn
The European Union's short-term tax targeted at digital advertising is aimed solely at U.S. tech companies Google Inc. and Facebook Inc. and enhances risks of trade retaliation, business tax lobbyists and researchers said.
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OECD pushes ideas for global corporate tax overhaul
The OECD has said there is growing consensus behind a US proposal for an overhaul of global corporate tax rules, as countries try to strike a deal on how to levy multinational companies in the digital era.
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Corporation tax cut to cost UK government coffers 12bn (pounds)
A planned cut in UK corporation taxwill cost the exchequer some £12bn by 2022, based on new estimates from HM Revenue & Customs that have enraged critics of the government's fiscal policy.
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Groups Examine Life Insurance Issues in Proposed GILTI Regs
Two insurance trade groups have requested changes to proposed regulations (REG-104390-18) on global intangible low-taxed income to address issues unique to the life insurance industry, including the use of section 954 reserve computations, the full inclusion election, and the determination of net deemed tangible income return.
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NAM Seeks to Fine-Tune Proposed GILTI Regs
The National Association of Manufacturers, commenting on proposed global intangible low-taxed income regulations (REG-104390-18), has asked the IRS to clarify the scope of the pro rata share antiabuse rule, clarify that section 245A applies exclusively to subpart F dividend income received by domestic and controlled foreign corporations, to eliminate the mandatory basis requirement, and to adopt an elective high-tax exception.
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Firm Requests Change to Proposed GILTI Regs
Mayer Brown, commenting on proposed regulations on global intangible low-taxed income (REG-104390-18), has requested the elimination of reg. section 1.951A-2(c)(5)'s application to section 197 amortization deductions for purposes of determining tested income or tested loss.
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24 Companies Tackle Computational, Other Issues Under GILTI Regs
Theworking Group for Competitive International Taxation has commented on proposed regulations (REG-104390-18) that provide guidance on global intangible low-taxed income, addressing three areas in computing GILTI and other issues regarding foreign-to-foreign dividends, pro rata antiabuse rules, and lower-tier controlled foreign corporation stock basis from previously taxed income.
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Global Insurers Seek Changes to Proposed GILTI Regs
EY, on behalf of several global insurance corporations, has asked that proposed global intangible low-taxed income regulations (REG-104390-18) clarify that a controlled foreign corporation's tested income or loss should be determinedwithout regard to a CFC's Subpart F income after applying any election in effect under section 952(c)(1)(B)(vii)(l).
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A SURE Way of Taxing the Digital Economy
In this article, the authors discuss tax reform efforts and the challenge of taxation and value creation in a digital economy.
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Japan Proposes Stricter Rules on Intangible Transfers, Interest
The Japanese government has submitted a draft law introducing significant new base erosion and profit-shifting measures, including a stricter interest expense cap and special rules for transfers of hard-to-value intangibles (HTVIs).
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SIFMA Outlines Suggestions for Proposed FTC Regs
The Securities Industry and Financial Markets Association has commented on proposed foreign tax credit regulations (REG-105600-18), addressing issues regarding interest expense, disregarded and intercompany transactions, carryovers, and accrual of foreign taxes.
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NYSBA Tax Section Comments on Proposed FTC Regs
Deborah Paul of the New York State Bar Association Tax Section has submitted a report on proposed foreign tax credit regulations (REG-105600-18), identifying some clarifications and changes to further the policies underlying the foreign tax credit regime.
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Councils Concerned With Changes to Foreign Corporation Info Return
The Information Technology Industry Council and National Foreign Trade Council have expressed concerns that some revisions to Form 5471, "Information Return of U.S. Personswith Respect To Certain Foreign Corporations,"will result in significant and costly administrative and compliance burdens, suggesting changes and a delay in the revised form's effective date.
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U.S. Tax Review (4)
In this article, the authors discuss recent U.S. international tax developments, including proposed anti-hybrid regulations and forthcoming regulations regarding foreign corporationswith previously taxed earnings and profits.
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EU Business Group Challenges Slovak Retail Turnover Tax
An EU trade group has approached the European Commission to complain about a new Slovak turnover-based retail tax,which it argued is incompatiblewith EU law and discriminates against foreign-owned companies.
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TCJA Won't End Disputes Over Transfer Pricing Regulations
Although the Tax Cuts and Jobs Act gave the IRS a clear statutory basis for transfer pricing interpretations historically rejected by the courts, the amendments' language and prospective effects suggest that taxpayer challengeswill continue.
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IRS Troubled by CFC Stock Sales as Potential Escape From GILTI
An IRS official stopped short of statingwhether guidance could target a "troublesome" situation inwhich a controlled foreign corporation stock sale avoids tax on subpart F income and global intangible low-taxed income tested income.
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U.S. Inversion Regs Won't Be Relaxed
The IRS isn't contemplating easing restrictions implemented by its anti-inversion regs in thewake of the Tax Cuts and Jobs Act.
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EU Retail Group Says Slovak Turnover Tax Discriminatory
A group representing European Union retailers said Monday that it had filed complaints to the European Commission against a turnover tax in Slovakia, saying the rule affects only non-Slovak businesses and constituted unlawful state aid. The group, EuroCommerce, said the Slovak retail tax violated the EU's rules on state aid and discriminated against companies' rights of freedom of establishment. The group said it had lodged two complaintswith the commission.
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Puerto Rico Gets Green Light For $18B Sales Tax Debt Plan
A plan expected to save Puerto Rico nearly $18 billion by restructuring debt carried by the Puerto Rico Sales Tax Financing Corp., or COFINA, got the go-ahead on Monday from the judge overseeing the U.S. territory's bankruptcy-like proceedings.
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Tax Reform Is Covering Its Costs
Is the 2017 tax reform paying for itself? It's a complicated question, but the critics have made up their minds. Outlets like the Tax Policy Center claim the Tax Cuts and Jobs Act has diminished federal revenue rather than increase it as some supporters predicted. Other skeptics lament surging government deficits and debt. Some point to last year's brief economic spurt as evidence of the law's failure to drive long-term growth. Even if one accepts these arguments, none of them offers a conclusion aboutwhether the tax cutwasworth its cost.
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For Some Companies, Tax-Cut Gains Are Smaller Than They Once Appeared
With earnings season in full swing, investors are starting to learnwhich companieswere overly optimistic about their tax cuts. Casino chain Las Vegas Sands Corp. has already taken a $727 million hit to its fourth-quarter profit, after a corporate tax regulation proposed in November made the 2017 tax overhaul less favorable than the company expected. International Business Machines Corp. said the same provision reduced its profit by $1.9 billion in the fourth quarter. As more companies report year-end results in comingweeks, investors can expect more dents in more bottom linesÔøΩplus, presumably, at least a few pleasant surprises.
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Why BEPS 2.0 makes tax heads nervous
Some tax directors are unimpressed by the direction of the OECD's digital tax proposals,with onewarning theywill bring "awhole newworld"withwide ranging implications.
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U.S. Chamber Suggests Fixes for Proposed Foreign Tax Credit Regs
The U.S. Chamber of Commerce has forwarded to the IRS a chart identifying problems in proposed foreign tax credit regulations (REG-105600-18) and the group's recommended solutions, asking in part for the expansion of the rules for specified partnership loans and additional guidance on the subpart F income group rules.
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EU Publishes Code of Conduct Letters
The EU Code of Conduct Group (Business Taxation) haswritten Barbados, Belize, Curacao, Mauritius, Saint Lucia, and Seychelles, requesting that they replace harmful preferential tax regimes to avoid being named on the EU Council's list of non-cooperative jurisdictions for tax purposes.
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Foreign Partners in U.S. Partnerships: TCJA and the ECI Rules
Some aspects of the U.S. international tax regime seem reasonably straightforward, conceptually speaking, but become confusingwhen applied to particular facts. One area that tends to fall into this category is the treatment of gains from the sale of property by foreign persons, as demonstrated by the U.S. Tax Court decision in Grecian Magnesite v. Commissioner.
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Global Digital Tax Talks Juggling Developing Countries' Goals
Developing countries' interests are playing into the global conversation toward consensus on the allocation of taxing jurisdiction in the digital era.
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EU Warns Watchlist Countries That New Regimes Are Still Harmful
The EU has informed the governments of six countries that legislation recently enacted to avoid the EU's blacklist of noncooperative tax jurisdictions fails to eliminate the harmful features of prior law.
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Missouri Guidance Treats GILTI as a Dividend
Missouriwill treat global intangible low-taxed income as a dividend for purposes of the state's corporate income tax.