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Brazil's Guedes Studying Dividend Tax to Pay for Corporate Cuts


Brazil's new economy minister reportedly told business leaders that the government is studying a plan to slash corporate tax rates and make up for the revenue hit by taxing dividend and interest payouts.

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EU to Agree on Merger, Whistleblower Proposals


EU member states are poised to agree onwhistleblower protections and harmonized procedures for cross-border mergers and divisions.

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Irish FM Calls for Focus on Value Creation in Digital Tax Debate


While Ireland opposes global minimum taxation as a long-term solution to tax digitalization,what's lacking in the ongoing debate is a focus on value creation as it relates to tax incidence, Ireland's finance minister said.

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U.S. Treatment of Losses in CFC Transactions Inconsistent


Practitioners have called into question inconsistencies in the treatment of transactions involving controlled foreign corporations that allow noneconomic and duplicative losses in some circumstances.

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Four former Fed chairs call for US carbon tax


Four former chairs of the Federal Reserve have joinedwith leading economists from both major political parties to issue an unprecedented call for a carbon tax in the US, saying "immediate" action is needed to address the risks of climate change.

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Taxpayers Can't Hide Much Globally Any More, OECD Official Says


Transparency and information-exchange efforts in the U.S. and around theworld are making it harder for multinational companies and tax evaders to hide information, an OECD tax official said.

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India Top Court Issues Notice to Tax Department on Vodafone Plea


Vodafone's India unit has taken the fight for refund of $675 million from Indian tax authorities to the country's top court,which agreed to hear the telecom company's in yet another tax battlewith the south Asian nation.

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Cyprus Rolls Out Anti-Tax Avoidance Directive


Cyprus has implemented the EU Anti-Tax Avoidance DirectiveÔøΩone of many taxation changes in Cyprus in 2019. In addition to the implementation of the Directive, 2019will be the first year inwhich the Cyprus tax authorities have to dealwith the new provisions for interest on back-to-back inter-company loans,which took effect on July 1, 2017.

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The Dublin Tax Inspector Comes A-Calling, Spooking Investors


With the recent tax demand for 1.6 billion euros ($1.8 billion) from Perrigo Co Plc and the news that Analog Devices Inc. faces a much smaller, but potentially significant, tax battle of its ownwith Ireland, the cases signal that Ireland is taking a tougher linewith U.S. companies using the nation to lower its taxes and as a gateway to Europe.

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Petrobras Loses Brazil Decision on $400M Foreign Profits Tax


Petrobras, Brazil's state oil company, is consideringwhether and how to appeal a $400 million tax fight loss at the hands of an administrative appeals court. The court on Jan. 17 upheld a revenue service assessment on the 2010 profits of Petrobras' subsidiary in Holland.

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France's Le Maire: Government Committed to Cutting Business Tax


French Finance Minister Bruno Le Maire said the governmentwould continue cutting taxes on businesswhatever the outcome of a public debate on policies.

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Belgium Mulls Plan to Tax Digital Companies


Belgium has become the latest European country after France, Austria and Italy, to begin discussions on taxing digital companies like Facebook Inc. Alphabet Inc.'s Google and Amazon Inc.

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India-Decision on Tax Treatment of Conversion of Preference Shares


The recent decision from the Income Tax Appellate Tribunal in the Periar Trading case in India on the tax treatment of the conversion of preference shares into equity shareswill have significance for foreign investors.

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From Greenspan to Yellen, Economic Brain Trust Backs Carbon Tax


An all-star lineup of economists, from Alan Greenspan to Paul Volcker, is endorsing a plan to combat climate change by slapping a tax on greenhouse gas emissions and then distributing the revenue to American households.

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Abolish Transfer Pricing to End Corporate Tax Avoidance, NGO Says


The global effort to stop corporate tax avoidance has failed because multinationals can still shift profits to very low-tax jurisdictions, a coalition of nongovernmental organizations said in a Jan. 17 report. The group calls for governments to find an alternative to transfer pricing, the system bywhich businesses assign value to their intercompany cross-border transactions.

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European Green Party Pushes EU Corporate Tax Reforms


The average effective corporate tax rate in the European Union is 15 percentÔøΩlower than the nominal rate of 23 percent because of sweetheart tax rulings, patent boxes, and other exemptions. That's according to a report from the European Green Party,which said the disparity underlines a corporate "race to the bottom" and the need for reforms to the bloc's corporate tax policy, including a common corporate tax base (CCTB) and public reporting of companies' global tax reports.

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How Amazon, Facebook Could Challenge Europe's Digital Taxes


Six European countries face inevitable legal challenges on new digital taxes they're imposing on the revenues of tech giants like Amazon.com Inc. and Facebook Inc., according to tax practitioners. Challengeswill likely arise at the start of 2020,when companies are first assessed for the tax, and an international trade dispute could begin brewing even sooner. Here are fiveways the tech giants challenge the taxes.

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South Korea Won't Scrap Stock Transaction Tax, Officials Say


The South Korean governmentwill keep the country's stock transaction tax despite calls from local brokerages to repeal it. An official of the finance tax division of the Ministry of Economy and Finance, Nam Han-sam, confirmed the government's position in an interviewwith Bloomberg Tax Jan. 17, a turnaround following an earlier Jan. 15 meetingwhere lawmakers indicated reform could happen.

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Record Malaysia Tax Revenue to Ease Pressure on Budget Deficit


Malaysia's intake of direct taxes rose to a record last year, easing pressure on a budget deficit that's expected to mark a five-year high.

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Spain takes another step towards 'Google tax'


The socialist government of Spanish prime minister Pedro Sánchez introduced a bill creating two new taxes on digital services and financial transactions based on the proposed EU-wide digital services tax thatwas stalled following opposition from several member states. Spain's versionwill levy a 3% tax on online advertising, online platforms, and sales of user data by companieswith global revenues of more than ÔøΩ750m that bring in at least ÔøΩ3m in digital services revenue in Spain.

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Apple, Amazon Awaiting EU Ruling on Tax Agreements


Multinational titans like Apple and Amazon have long sought out more favorable tax arrangementswith European Union governments. The extent towhich the European Commission is able to rein them in could become clearer this year. The Commission has already issued decisionswhich say that Apple, Amazon, Fiat and Starbucks received unlawful state aid in the form of preferential transfer pricing rulings that let the companies shift profits to avoid paying taxes; the companies have appealed the decisions to the European General Court.

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Tax Planning Woes Hit Foreign Entities as Shutdown Lingers


Certain types of foreign entities like limited liability companies and partnerships are trying to make a "check-the-box" election on how to be taxed in the U.S., but they can't because of a procedural hang-up caused by the government shutdown.

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Ocasio-Cortez Buzz Hits Davos as Dalio Says 70% Tax Talk to Rise


Threeweeks after the Congresswoman Ocasio-Cortez called for an income tax rate of as much as 70% on thewealthiest Americans, billionaire investor Ray Dalio suggested that the idea may have legs in the run up to the U.S. presidential election. Discussing the outlook for a slowingworld economy, Dalio said that next yearwill see "the beginning of thinking about politics and how that might affect economic policy beyond. Something like the talk of the 70 percent income tax, for example,will play a bigger role."

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Brussels to sue UK over tax breaks for commodities traders


Brussels is to sue the UK in Europe's highest court over tax breaks for commodities traders, according to EU diplomats briefed on the plans, escalating a battle that Britain said risked damaging the post-Brexit competitiveness of the City of London.

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Luxembourg Tax Reform--Impact on Distressed Debt Investments


Investments into distressed debt are an important niche market of the Luxembourg fund industry. The new interest deduction limitation rule may have a significant impact on the overall tax profile and reduce returns on these investments.

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Colombia 30-Year Bond Tests Investor Demand After Tax Bill Flop


Colombia is returning to the global bond market in the first test of investor appetite for the nation's debt since congress blocked the government's tax raising plans last year.

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Australia Considers Tracking $10.8B Gig Economy Income For Tax


Australia launched a consultation Jan. 23 on how itwill track underreported tax among users of sharing economy platforms like Uber Technologies Inc. and Airbnb Inc.

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Green Party Warns EU About Brexit and U.K. Tax Havens


The EU must insist that the U.K. force its overseas territories and crown dependencies to adopt transparency rules that require companies to disclose their owners as part of any future post-Brexit trade relationship.

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Fresh Push for Public Tax Reporting Under EU Romanian Presidency


European Union presidency holder Romaniawill try Jan. 24 to jump start pending legislation to require multinational companies to make public their tax and profit reports,which they currently prepare for jurisdictions inwhich they have operations.

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Interest Write-Off Rules Will Likely Generate Broad Backlash


Corporate debt could now get more expensive under the 2017 overhaul, particularly for oil and gas refiners. The law capped the amount of interest payments companies canwrite off their tax bills. For many oil and gas refiners, aswell as manufacturers and retailers, their ceiling could be much lower than expected and more of them could become subject to the limit several years earlier than expected.

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Brazil's Petrobras Receives Unfavourable Tax Ruling

  • By Reuters

Petroleo Brasileiro SA (Petrobras) has received an unfavourable ruling from a tax court in a 1.7 billion reais (344.85 million pounds) dispute involving corporate tax charged in 2012 on overseas companies it controlled, the Brazilian state-run oil company said in a securities filing onwednesday.

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Taxing Where Value is Created: What's 'User Involvement' Got to Do With It?


In this paper, authors offer a pragmatic and contextualised analysis of the new "value creation" paradigm, and on this basis, authors examine its implications for international tax policy in the era of digitalisation. A special focus is put on the role of users (especially of online platforms) that are said to contribute to value creation e.g. by forming valuable networks, by providing data or by posting online content.

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Highlights of the final 'toll tax' regulations under Section 965

  • By PwC

PwC summarizeshighlightsof the final 'toll tax' regulations under Section 965 released on January 15. The Final Regulations provide guidance relating to the 'toll tax' due upon the mandatory deemed repatriation of certain deferred foreign earnings.

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Upcoming US 10k filings to offer clues BEAT and GILTI compliance


Bankswill be examining the February 10k filings of their competitors to see how they are dealingwith the BEAT and GILTI provisions in the US TCJA.

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EU Court to Hear Case on French Tax on Merger-Related Capital Gains

  • By Tax Analysts

The Court of Justice of the European Unionwill consider a French case (C-672/18) onwhether the EU merger directive (2009/133/EC) precludes the use of different assessment bases and rate rules to tax capital gains from the transfer of securities received in exchange during a merger and deferred capital gain.

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U.S. Tax Review (5)


In this article, the authors discuss recent U.S. international tax developments, including new regulations dealingwith foreign tax credits and interest expense deductions for companies.

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Romania Outlines Presidency's Objectives to EU Lawmakers


The proposal for a digital services taxwill be reconsidered during the Romanian presidency of the EU Council, Finance Minister Eugen Teodorovici told lawmakers.

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EU's Low Effective Tax Rates Reveal Effects of Tax Competition


Data suggest that tax competition among EU countries has allowed multinationals to pay tax at rateswell below the statutory corporate rate,which in some member states is more than double the effective tax rate (ETR).

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OECD Advisory Group Sets Out Framework for Digital Tax Reform


An OECD advisory committee has taken aim at unilateral actions and underscored the impossibility of ring-fencing the digital economy in a paper containing 11 recommendations for international tax measures in the digital age.

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Spain Proposes Digital Services and Financial Transaction Taxes


Spain's government has asked parliament to approve a digital services tax and a tax on financial transactions that it saidwill generate over ÔøΩ2 billion in revenue annually.

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Treatment of Interim PTEP Distributions Draws Ire


The treatment of interim distributions of non-section-965-related previously taxed earnings and profits (PTEP) that do not benefit from a gain reduction rule appears at oddswith the PTEP regime, according to practitioners.

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Transfer Pricing Regimes: Hong Kong vs Singapore


The two markets of Hong Kong and Singapore are often comparedwith each other, however,where their transfer pricing regimes are concerned there are differences. Singapore and Hong Kong have reached significant milestones in their transfer pricing regimes.what are the differences between their regimes?

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Outside Groups Get Legal Standing in Canada Carbon Tax Case


Over a dozen environmental groups, Indigenous representatives, and health advocateswill have their say in court this April in support of Canada's carbon tax. Ontario Court of Appeal Justice James MacPherson granted the groups standing Jan. 15 to participate in the case thatwill consider the constitutionality of the federal Greenhouse Gas Pollution Pricing Act.

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Chile Seeking March Deal to Reduce Corporate Taxes


Chile's government and opposition lawmakers are negotiating terms of the government's tax proposalwith the aim of reaching a deal by March, Finance Minister Felipe Larrain said.

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Wall Street Analysts Urge Caution on Tax Cut's Boost to Earnings


The U.S. tax overhaul's boost to corporate profits could start to diminish soon as the effects of new international taxes and restrictions on interest deductions take hold, according to a research note from Morgan Stanley.

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Here's How U.S. Businesses Actually Used Their Tax Cuts


On Jan. 1, 2018, the biggest, most sweeping U.S. corporate tax cut ever enactedwent into effect. A year later,we're able to see how businesses used all that extra cash. The short answer: to buy back shares. The long answer is slightly more nuanced, but not by much.

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IRS Issues Final Regulations on Repatriation Tax


The Internal Revenue Service released final rules on the one-time tax multinationals must pay on accumulated overseas earnings and profits.

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Treasury releases final Section 965 regulations

  • By PwC

Today, Treasury released final regulations under amended Section 965 ('the toll charge') and submitted them for publication in the Federal Register. PwC summerizes the final 965 regulations that provide guidance relating to the toll charge due upon the mandatory deemed repatriation of certain deferred foreign earnings.

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Puerto Rico Creditors Press For Sales Tax Plan Approval


Major stakeholders engulfed in Puerto Rico's bankruptcy-like proceedings urged a federal judge onwednesday to approve awatershed settlement designed to restructure nearly $18 billion in debt carried by the Puerto Rico Sales Tax Corp., or COFINA, saying it is the bestway to avert years of protracted litigation.

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The U.S. Economy and 'Neighbor Envy'


This could get awkward. Former Obama economic adviserswho claimed tax reformwouldn'twork have been miserable enoughwatching U.S. growth defy their predictions. Now they may have towatch other countries repeat the U.S. success as governments overseas consider lowering their corporate income tax rates.

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