US says digital taxes in Spain, Austria and UK are discriminatory

By: Aime Williams

The US has said that digital taxes in Spain, Austria and the UK are discriminating against American tech companies, paving the way for tariffs and setting the scene for transatlantic trade conflict as the Biden administration takes power.

Germany seeks global corporate tax deal with Biden administration

By: Guy Chazan

German finance minister Olaf Scholz has said he will seek a deal with the incoming Biden administration on global rules for corporate taxation, as hopes rise in Berlin that the end of the Trump presidency will usher in a new era of multilateral co-operation.

Stakeholders Push for ‘Angel List’ in OECD Minimum Tax Plan

By: Stephanie Soong Johnston, Ryan Finley

One way to simplify the OECD’s overly complex global minimum tax plan and lighten administrative burdens is for tax administrations to identify low-risk jurisdictions with appropriate tax bases and rates, businesses and tax advisers said.

First TCJA Suit Filed Against a State Taxing Repatriated Income

By: Amy Hamilton

The Council On State Taxation has filed the nation’s first lawsuit challenging a state’s treatment of a Tax Cuts and Jobs Act provision.
At issue in Council On State Taxation v. Nebraska Department of Revenue, pending in the District Court of Lancaster County, Nebraska, is the Department of Revenue’s disallowance of any state deduction claimed for section 965 deemed repatriations.

U.S. Slams Digital Taxes of Austria, Spain, and U.K. as Unfair

By: Amanda Athanasiou

The Office of the U.S. Trade Representative (USTR) has found that the digital taxes of Austria, Spain, and the United Kingdom discriminate against U.S. businesses, but has again held off on announcing retaliatory trade actions.

U.S. Must Rethink Stance on Global Tax Reform Deal, Harter Says

By: Kiarra M. Strocko, Stephanie Soong Johnston

A little-publicized German proposal floated in 2020 may be the key for the Biden administration to open the door to a global tax reform deal in 2021, Treasury’s former top international tax policy negotiator said.

EU Assessing Impact Digital Tax Would Have on SMEs, Consumers

By: Sarah Paez

The European Commission has released information about the potential scope and impact of a digital levy that will be pursued if OECD countries fail to reach an agreement on new international tax rules by June.

An Argument for Eliminating Subpart F Income

By: Anonymous

To the Editor:

In a recent article, Martin A. Sullivan criticizes the complexity of the Biden campaign’s tax agenda and makes a persuasive case for pursuing the same goals by simpler means (Sullivan, “Biden's Incoherent Corporate Tax Policy,” Tax Notes Federal, Jan. 4, 2021, p. 9). While President-elect Biden’s campaign proposals have been heavily dissected since he secured the Democratic party nomination, and even more so since he won the presidency, Sullivan’s focus on simplicity is a welcome addition to the discourse. What Sullivan did not discuss, however, is the fact that the Biden campaign’s proposals for global intangible low-taxed income would meaningfully simplify current law. Moreover, under one of Sullivan’s own recommendations, an even greater simplification of our international tax system is easily within reach.

U.S. Threat of Digital Tax Retaliation Unjustified: EU Official

By Stephen Gardner

U.S. President-elect Joe Biden should drop threatened countermeasures against European Union taxes on mainly American digital platforms, one of the bloc’s top finance officials said Tuesday.

EU Preps to Tax Big Tech; Expands Call for Digital Tax Feedback

By: Stephen Gardner

The European Union is seeking stakeholder input on how a digital tax might be introduced in the bloc. The European Commission, the EU’s executive, announced Tuesday that it would accept comments through April 12 to a questionnaire on issues including the minimum revenue thresholds above which a digital levy would apply, specific digital activities that might be taxed—such as platforms’ sale of user data—and how taxable revenue can be delimited geographically. For example, should the proposal use the IP addresses of digital service users.