Int'l Tax News

Large and multinational companieswill get a boost under New Zealand's new research and development tax plan. The new tax incentive, announced Oct. 3 and set to operate from 2020, gives the large and global firms access to an incentive scheme fromwhich they've previously been excluded.

Ongoing budget negotiations between Spain's minority Socialist government and the leftist Unidos Podemos alliance could bring a higher top income tax rate and more tax agency scrutiny for popular investment schemes.

Officials from theworld's largest economies are calling on the OECD to consider changing theway multinational companies are taxedworldwideÔøΩinspired in part by U.S. tax reform saidLafayette G. "Chip" Harter, deputy assistant secretary of international tax affairs at the Treasury Department's Office of Tax Policy.

The government took the biotechnology and pharmaceutical industries' unique financing into account in its decision to consider relaxing rules for spinoff transactions. The Internal Revenue Service announced Sept. 25 that itwas reassessing requirements that units to be spun off of a corporation generate revenue prior to the transaction.

The U.S.will speak up for its foreign-derived intangibles income regime at the recent OECD forum. This article provides updates on spinoffs; applying the 2017 tax law's provisions to corporations at the consolidated group level; and the push for uniform state approaches to partnership audits.

Airbnb's tax arrangements have come under scrutiny from UK authorities, intensifying pressure on the home-sharing app that has transformed the market for short-term holiday rentals since its launch in 2008.

The Czech Republic joined opposition by Ireland, Finland and Sweden to the European Union's proposed tax on big Internet companies in a joint paperwarning that the measures may breach international treaty obligations.

Chinawill increase export tax rebates from Nov. 1 and quicken export tax rebate payments to support foreign trade, the cabinet said on Monday, as a tradewarwith the United States escalates.

Canada is lagging behind its peerswhen it comes to reviewing and reforming its tax system, and there's a real risk that the country's tax competitiveness is on the decline, an accountancy group has said.

The outgoing inspector general of the Australian Taxation Office (ATO) has recommended that an oversight authority be created to supervise the agency, similar to management boards in Canada, the United Kingdom, and the United States.

India's new framework for determining significant economic presence (SEP) is having little impact because key questions regarding the thresholds for establishing a presence have yet to be answered, a practitioner said.

Support is growing for beneficial ownership transparency (BOT) in the United States,which has become inundatedwith "authoritarian capital" from other countries, according to an independent agency of the U.S. government.

Congress may have intended to require a causal relationship between the hybrid nature of a transaction and the application of a preferential regime in order to deny a deduction, according to an IRS official.

Despite predictions that the OECD's base erosion and profit-shifting projectwill cause a surge in international tax controversy, giving tax authorities the same information from the beginning may actually help multinationals avoid disputes.

Karen Sowell of the New York State Bar Association Tax Section has submitted a report on proposed transition tax regulations (REG-104226-18) under section 965, addressing the double counting rule, refunds for taxpayers making the section 965(h) election, clarification of the domestic passthrough entity, and many other aspects of the regs.

The IRS is standing by its refund policy for overpayment of the transition tax in the face of strong practitioner criticism, though the agency admits that the issue is not yet closed.

The IRS is nearly finished drafting proposed regulations setting the groundwork for implementing the Tax Cuts and Jobs Act's international provisions,which have gained international recognition as a possible model for consensus anti-profit-shifting measures.

Dutch Prime Minister Mark Rutte said his governmentwould reconsider plans to scrap its dividend tax in a major political climbdown only hours after Unilever dropped plans to move its headquarters to the Netherlands. Rutte,who had argued that getting rid of the 15 percentwithholding tax on dividendswas vital for the country's business climate, said his government must reconsider its entire package of tax reforms.

The Tax Cuts and Jobs Act's reduction in corporate income tax rates has revived the popularity of C corporation entity structures, but practitionerswarned Thursday there is no one-size-fits-all choice for every business.

Failing to participate in the global digital tax debatewould be a mistake the USwould regret, say a senior tax executive and former Microsoft tax counsel.

A bloc of Eastern European states said Friday that theywere supporting the European Union's temporary digital tax. The statement of finance ministers from the so-called Visegrad Group signals a core of support for the controversial tax,which has divided European Union member states since the continent's executive arm, the European Commission, proposed the idea in March.

Tax administrations need to harmonise their tax filing and data requirements to give taxpayers a better chance of complying, say in-house practitioners and tech aficionados.

A financial services firm's French branch shouldn't be allowed to deduct VAT for transactions undertaken for its London headquarters thatwouldn't be deductible in both the United Kingdom and France, an advocate general has recommended.

An OECD-U.N. program created to strengthen tax auditing capacity in developing countries has reported yet another year of good progress, helping tax administrations claw back more than $400 million in additional tax revenues to date.

Despite Trump's import taxes, US trade gap rises for third straight month to $53.2 billion in August.

Nearly 100 non-EU countrieswould have to require multinational companies to report their taxes and profits on a country-by-country basis under proposed criteria for the bloc's tax haven blacklist.

Japanese automakers doubt the viability of U.S-Japan bilateral advance pricing agreements saying the IRS has become increasingly aggressive in its audits, and rather seek legal relief through U.S. courts. APA negotiations between the U.S and Japan are set to take place in mid-October.

Multinational corporations scrambling to meet IRS filing deadlines have more time to make basis adjustments under the new transition tax.

Law professors are on the IRS's side in a federal court case involving Intel subsidiary Altera Corp., as the agency and company prepare for a second round of arguments in the highlywatched tax case. Legal professors from around the country urged the U.S. Court of Appeals for the Ninth Circuit to keep its original ruling and accept the IRS's 2003 regulation that requires domestic companies to sharewith their foreign units the cost of stock compensation granted to employees.

Britainwill unilaterally implement a digital service tax if there is nowider international agreement soon on how to tax theworld's biggest internet companies, finance minister Philip Hammond said on Monday.

The new concepts of virtual, or digital, permanent establishment and its tax treatment are creating a challenge on a global scale. Part 1 in this series looks at the latest initiatives being taken at domestic and OECD levels.

Australiawants feedback on plans to tax large digital businesses, as part of government efforts to ensure online companies are taxed as fairly as businesses based in the country.

Calls are mounting for tax reform in Germany as its multinational companies are increasingly investing in the United States. Recent U.S. tax reform has set up a business-friendly environment that German automotive, pharmaceutical, and mechanical firms in particular just can't resist, according to Carsten Brzeski, chief economist at ING-DiBa in Frankfurt.

Intel subsidiary Altera Corp. and the IRS are gearing up for another tax showdown as the two parties and their supporters filed myriad briefs to try again towin over a federal appeals court.

European Union finance ministers decided on Tuesday to allow lower sales taxes on e-books and other digital publications and to align them to reduced levies applied to paper versions of books and magazines.

The new concepts of virtual, or digital, permanent establishment and its tax treatment are creating a challenge on a global scale. Part 2 in this series looks at the steps being taken by the European Union to address the challenges presented by the digital permanent establishment.

Businesses in Saudi Arabia and the United Arab Emirates are having to look again at their operation designs, as they continue to struggle under a fledgling value-added tax regime.

The Netherlands plans to trim a tax break that lets foreignworkers in specialized fields receive 30 percent of their salary tax-free. The length of the benefitswill change to five years from eight years, retroactively, soworkers more than five years into existing agreementswill be immediately cut off on Jan. 1, 2019.

Israel lacks legally binding regulations for resolving multinational cross-border tax disputes, a gap the OECD and practitioners hopewill be addressed in guidance coming next year.

The Medtronic dispute involves the transfer pricing methodology and the allocation of income between Medtronic and its Puerto Rican subsidiary relating to intercompany licensing of intangible property for the manufacture of medical devices and leads by the subsidiary. This paper addresses the IRS deficiency notice in the amount of $1.4 billion, Medtronic's challenge and victory in the tax court, and the overturn in appealswith focus on the need for strict adherence to the tax regulations.

Corporations doing debt-for-debt exchanges in tax-free spinoffs are getting more certainty from IRS guidance that standardizes theway they can ask for private rulings on the deals.

In a brief for the Third Circuit, a partnership argued that section 956(d) regulations are invalid and urged the court to reverse a Tax Court decision that upheld the validity of the regulations and held that the partnership had income inclusions taxable as ordinary income from two controlled foreign corporations that guaranteed U.S. obligations.