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Int'l Tax News

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Coal Company Seeks GILTI Guidance on Overseas Mineral Interests

  • By Tax Analysts

Peabody Energy has requested clarification on the determination of qualified business asset investment for mineral interests held overseas for purposes of computing global intangible low-taxed income (GILTI) for U.S. shareholders, noting that proposed GILTI regulations (REG-104390-18) do not specifically address those interests.

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Firm Submits Proposal to Provide Relief Under Transition Tax Regs

  • By Tax Analysts

Davis Polk &wardwell LLP has submitted a proposal on behalf of a client that seeks to provide taxpayer relief from an approach adopted by proposed section 965 regulations (REG-104226-18) to address circumstances inwhich a foreign corporationwas repatriated into a domestic corporation before November 2, 2017, in a transaction governed by section 381.

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ABA Tax Section Looks to Refine GILTI Regs

  • By Tax Analysts

The American Bar Association Section of Taxation has submitted a report on proposed regulations (REG-104390-18) on global intangible low-taxed income, recommending that portions of the regs be reconsidered and suggesting clarification of other provisions.

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Deloitte Tax Seeks Reg Changes for GILTI Deduction Purposes

  • By Tax Analysts

Deloitte Tax LLP has asked Treasury and the IRS to amend the applicable regulations under section 962 to provide for a reduction in taxable income to take into account the global intangible low-taxed income deduction allowed by section 250(a)(1)(B), explainingwhy that change is needed to restore compatibility of those regswith the tax code.

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Corporation Wants Answers on Treatment of Outbound Transfers

  • By Tax Analysts

Brunswick Corp. has urged Treasury to modify the final section 367 regulations on the treatment of some property transfers to foreign corporations, stating that the prospective application of the repealed active trade or business exception under the Tax Cuts and Jobs Act (P.L. 115-97) creates confusion regarding transfers that occurred before the TCJA's enactment.

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Clarification of FDII Rules for Cross-Border Transportation Sought

  • By Tax Analysts

An individual, referencing a letter from United Airlines, has commented on the foreign-derived intangible income provisions in the Tax Cuts and Jobs Act (P.L. 115-97) and requested guidance on how theywill affect cross-border transportation services income, specifically regarding apportionment methodology.

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Foreign Bankers Seek Fix for Unintended Consequence of TCJA

  • By Tax Analysts

The Institute of International Bankers has requested guidance to eliminate new U.S. tax reporting obligations on some foreign subsidiaries of foreign banks, saying that controlled foreign corporations created due to the repeal of section 958(b)(4) should not be treated as U.S. payors for purposes of Form 1099 reporting and backupwithholding.

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How the Netherlands Is Cleaning Up Its Tax Act


In this article, the author examines Dutch efforts to address corporate tax avoidancewithout pushing away foreign investors.

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Facebook Settles Italian Tax Dispute for Over $100 Million


The Italian Revenue Agency announced that Facebook's domestic subsidiary has agreed to pay more than ÔøΩ100 million to settle a tax dispute.

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Moscovici Tempers Hope for Year-End Deal on Digital Services Tax


Time is running out for EU countries to reach an agreement on the European Commission's proposal for a digital services tax by the end of the year, EU Tax Commissioner Pierre Moscovici has admitted.

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Regs Offer Complex Scheme for CFCs' Interest Deduction Limits


Proposed regulations tackle issues that arisewhen applying the business interest deduction limitation to controlled foreign corporations, albeit at the cost of complexity.

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Bill Sides With Taxpayers on U.S. Transition Tax Overpayment Fix


Buried deepwithin the House's freshly introduced tax legislation is a provision thatwould allow taxpayers to receive refundswhen making overpayments on the transition tax, potentially resolving a highly contentious issue.

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EU Digital Tax to Apply From 2022, Compromise Proposal Says


In the latest push to convince EU member states that are either undecided about or opposed to adopting an EU-wide digital services tax (DST), the Austrian EU presidency has proposed delaying its application until 2022.

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Tech Tax Advocates Said to Prepare Last-Ditch Push for EU Deal


Proponents of a tax on the European revenue of tech giants are preparing a last-ditch push for a deal thisweek, amid continuing resistance to a levy that divides the region's governments and threatens to fragment its single market.

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Global Firms' Indian Back Offices Face Tax Trouble


India's lucrative outsourcing companies are pushing the government toweigh in after a recent ruling suggested they could face heftier tax bills, spooking the foreign businesses that rely on them.

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OECD Releases Global Forum Statement of Outcomes

  • By Tax Analysts

he OECD has released a statement outlining the implementation of information exchange methods now in use, such as the Automatic Exchange of Information, the Exchange of Information on Request and the effort the Global Forum is putting forth to secure a level playing field through identifying jurisdictions that may be relevant to thework of the Global Forum following the eleventh meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes.

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CJEU Finds France Can't Withhold Tax on Dividends Paid to Nonresident Companies

  • By Tax Analysts

he Court of Justice of the European Union in Sofina SA, Rebelco SA, Sidro SA v. France, C-575/17 (CJEU 2018), held that articles 63 and 65 of the Treaty on the Functioning of the European Union preclude France fromwithholding tax on dividends paid to nonresident companieswhile not taxing similar loss-making resident companies, finding that such treatment amounts to a restriction on the free movement of capital.

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It's Only Make-Believe . . .


"Deeming" provisions are often introducedwithin antiavoidance legislation and can often produce unexpected, unreasonable, and absurd resultswhen taken literally. In this article, the author looks at a recent decision of the U.K. Upper Tribunalwhere common sense prevailed over the letter of the law.

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NYSBA Members Concerned With Complexity of Rules Under GILTI Regs

  • By Tax Analysts

Karen Sowell of the New York State Bar Association Tax Section has submitted a report on proposed regulations (REG-104390-18) on global intangible low-taxed income, supplementing a prior report to reiterate some suggestions thatweren't adopted in the regs and raising concerns about the complexity created by various basis adjustment rules.

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NYSBA Has Problems With GILTI's Antiavoidance Rule


Add the New York State Bar Association Tax Section to the list of parties that have taken a strong stance against the global intangible low-taxed income proposed rules' antiavoidance provision aswritten.

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Switzerland To Adopt Global Forum's Tax Recommendations


The Swiss Government is to press aheadwith its plans to implement the recommendations made by the OECD's Global Forum on Transparency and Exchange of Information for Tax Purposes, despite domestic opposition.

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Business groups brace for Dem push to hike corporate taxes


The business community is bracing for Democratic proposals to raise the corporate tax rate to pay for infrastructure spending and other priorities. Infrastructure is seen as one of the rare areaswhere Democrats and President Trump might be able to come to a deal, since both sides have called for improvements to the nation's roads, railways and bridges. The problem is how to pay for the new spending.

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UAE Dangles Billions of Dollars Before Brazil, with One Catch


The United Arab Emirates iswilling to expand its multi-billion dollar investments in Brazil as long as it's no longer labeled a tax haven by Latin America's largest economy.

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Changes to New Zealand R&D Tax Incentives


This article discusses the recent changes to tax incentives in New Zealandwhich are intended to increase corporate investment in research and development.

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GM Didn't Invest Tax-Cut Proceeds in the U.S., Ohio Lawmakers Say


General Motors,which is closing five North American factories,was criticized by lawmakers in Ohio,with Sen. Sherrod Brown (D-Ohio) accusing the automaker of using the benefits of last year's tax cut to invest in Mexico.

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US capital expenditure boom fails to live up to promises


In this opinion article, the author discusses the recent tax cuts effect on the US economyÔøΩthe Trump administration claims the corporate tax cutswould spur huge investment and growth, raisingwages and ushering a new era of bullishness. Not quite.

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Amazon Lifts Ban on Australians Shipping From Its Main Site


Amazonwill grant Australians access to products from its mainwebsite,walking back a decision made earlier this year that angered its customers in the country. The online retailer had announced that itwould redirect Australians to a localwebsite to complywith changes to Australian tax lawwhich requires online retailers to impose a 10 percent goods and services tax on items sold and shipped from overseas.

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China Exempts Foreign Investors From Bond Market Taxes

  • By Reuters

Foreign investors in China's onshore bond marketwill be exempt from taxes for the next three years, China's Ministry of Finance said Thursday.

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Caricom to Waive Taxes on Oil as Petrotrin Refinery Closes

  • By The Associated Press

A Caribbean trade bloc is removing taxes on imported oil and petroleum products for the region as a major refinery on the island of Trinidad prepares to close.

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Canada to Offer Tax Credits and Incentives to Media

  • By The Associated Press

Canada's federal government saidwednesday it is stepping in to help the struggling Canadian media industrywith new tax credits and incentives.

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The Engie State Aid Decision - Another One Bites the Dust


The European Commission has ruled that Luxembourg granted illegal state aid to Engie, but the Luxembourg government disagrees. On September 6, 2018, the European Commission released its decision of June 20, 2018 regarding the Engie state aid investigations. The Commission ruled that Luxembourg granted illegal state aid to Engie and should collect around 120 million euros ($136.5 million) of taxes from the company.

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Australia - Restructure of Hybrid Mismatch Arrangements and Tax Avoidance Guidance


The Australian Taxation Office has issued final guidance to assist taxpayers to manage their compliance risk by outlining straightforward low risk restructuring towhich theywon't seek to apply tax avoidance provisions.

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European Commission Finds no Illegal State Aid


In a significant decision, the European Commission found that Luxembourg did not grant illegal state aid to McDonald's. However, multinational groups that still operatewith hybrid permanent establishments should carefully analyze upcoming tax law changes.

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Shell Company Testimony Drives EU Lawmaker Demand for Crackdown


The European Union needs to put pressure on member states to do awaywith the kind of shell companies that attract tax avoidance and money laundering, according to Jeppe Kofod, spokesman for the European Parliament's committee that focuses on financial crime.

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Business Lauds Trudeau's Tax Relief but Says More Could Be Done


Justin Trudeau spent awindfall on billions in tax breaks for Canadian businesses. Their response is that he still haswork to do.

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Canada Offers $10.6 Billion in Incentives to Counter U.S. Tax Reform


Canada is offering tax incentives totaling C$14.0 billion ($10.6 billion) to offset the impact of President Donald Trump's tax reforms on the country's ability to compete for capital investment.

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Interest Spikes as Hungary Moves to Offer Group Tax Loss Relief


Companies that fallwithin a group structure are keen on Hungary's latest plan to help them reduce their collective tax by sharing corporate tax losses. The optionwould let affiliated companies set up a corporate tax group. Further, the planwould make it possible for these companies to eliminate the need to prepare domestic transfer pricing documentation.

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EU Banking Industry Calls for Blanket Exemption From Digital Tax


Bankers are piling the pressure on the European Union to ensure all financial services receive a blanket exemption to the bloc's pending 3 percent digital services tax.

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Tax Professionals Grapple With EU Transparency Challenges


Companies in Europe are being advised towork now to complywith new rules requiring them to report certain aggressive cross-border tax planning arrangements to national tax authorities.

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EU Tech Tax Could Take Effect by 2022 at Latest, Document Says


The European Union's digital tax geared at clawing back money from tech giantswould take effect in member states across the bloc by 2022 at the latest, according to a draft outlining a compromise legislative proposal by Austria,which holds the EU's rotating presidency.

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Oil Giants Push for Details on BEAT, Foreign Tax Credits


Some of the biggest oil companies are looking for details on how to navigate the transition between the old U.S. international tax system and the new one. Representatives from the American Petroleum Institute and a number of major energy companies metwith officials from thewhite House's Office of Management and Budget on Nov. 19 to talk about soon-to-be-released proposed regulations and guidance on foreign tax credits and the base erosion and anti-abuse tax. The group is asking the OMB to include transitional details in those proposed regulations that clarify how the 2017 tax law treats net operating losses a company accrued before the law passed, and how companies can apply their old foreign tax credits under the law.

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Tax Legislation 'Blue Book' Coming: What It Is, Why It Matters


The nonpartisan Joint Committee on Taxation is set to release its explanation of the 2017 tax law soonÔøΩwhat's known as the "blue book." It may be the most anticipated edition yet of the publication.

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Deere, Gap Report Smaller Tax Law Charges


Foot Locker Retail Inc., Gap Inc., and Deere & Co., commonly known as John Deere, all revised down their one-time 2017 tax overhaul payments in their most recent quarters.

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Liberty Mutual, Chubb Seek 'GILTI' Tax Fix


U.S. insurance companies can be taxed twice on foreign earnings under one of the international provisions in the 2017 tax overhaul, even if those profits have been taxed highly elsewhere, insurers told the Treasury Department.

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Only Tax-Compliant Firms To Be Allowed Australian Gov't Contracts


Australia is to require businesses seeking to tender for significant federal government procurement contracts to demonstrate their record of tax compliance. From July 1, 2019, tenderers for procurement contractsworth over AUD4m (USD2.9m) (inclusive of goods and services tax)will need to provide a statement from the Australian Taxation Office (ATO) to show that they have a satisfactory tax record.

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Countries disagree on advantages of MLI 'synthesised texts'

  • By International Tax Review

Jurisdictions are beginning to create 'synthesised texts' to help taxpayers understand how the OECD's multilateral instrument (MLI) interactswith bilateral double tax treaties, but some believe they do not offer the legal clarity taxpayers seek and risk future disputes.

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Technology Improving Tax Systems In Some Countries: Report


While some economies have continued to integrate new technology to improve their systems for the benefit of taxpayers aswell as tax authorities, other countries have trailed behind, introducing new taxeswithout technological advances, according to a report releasedwednesday by PwC and theworld Bank.

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Canada Unveils Tax Incentives to Offset Trump Effect


Canada onwednesday unveiled billions in economic measures aimed at jump-starting lackluster business spending and countering the risk of lost investment to the U.S. stemming from the Trump administration's tax reform.

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White House's Kudlow: Tax Reform's Next Phase Won't Happen in 2018

  • By Reuters

White House Economic Adviser Larry Kudlow told reporters on Tuesday the next phase of U.S. tax reformwill not happen during the final months of 2018, the "lame duck" periodwhen Republicanswill still control Congress.

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One Thing Investors Don't Need to Worry About


Tuesdaywas another down day in the markets amid concerns about global growth, U.S. interest rates and President Donald Trump's trade disputewith China. But investors suffering high market anxiety fortunately do not need towonderwhether tax competitivenesswill help the U.S. in the long run.

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