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The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
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BEPS Primer: Past, Present, and Future
By: Jeffery M. Kadet
In this two-part article, the author updates his examination of the initial OECD base erosion and profit-shifting project, and he considers the process and potential success of BEPS 2.0. This first installment examines the origin of the BEPS project, its objectives, and how it may proceed in the future. The second installment will focus on BEPS 2.0.
To read more go here Subscription RequiredAuthority Questions Arise for FDII Heightened Substantiation
By: Andrew Velarde
Treasury’s decision to base its substantiation requirements for some foreign-derived intangible income transactions on those of two other tax code provisions may lead to taxpayers questioning the authority upon which it rests.
To read more go here Subscription RequiredThe Trouble With ‘Pillars’ in International Tax Policy
By: Lucas De Lima Carvalho
In this article, the author discusses the OECD’s two-pillar approach to taxing the digital economy. He focuses on the narrative of “pillar-building” in international tax policy and the difference between building consensus and manufacturing consent.
To read more go here Subscription RequiredOECD Sketches Out Progress on Global Tax Reform Blueprints
By: Stephanie Soong Johnston
The OECD has made good progress on designing a global tax reform plan, but stakeholders may need to be realistic about the prospect of countries agreeing on that plan by year-end, officials said.
To read more go here Subscription RequiredU.K. Digital Services Tax Becomes Law, Stoking Trade Tensions
By: Stephanie Soong Johnston
The U.K digital services tax has become law, setting the stage for escalating trade war tensions between the United Kingdom and the United States, which is investigating whether the tax discriminates against American business interests.
To read more go here Subscription RequiredCost-Sharing Arrangements May Have Less Appeal Post-TCJA
By: Ryan Finley
The Tax Cuts and Jobs Act’s amendments to the definition of intangible property and codification of the aggregation and realistic alternative principles may discourage taxpayers’ use of cost-sharing arrangements in the future.
To read more go here Subscription RequiredEuropean Parliament to Renew Push for EU Taxes
By: Jean Comte
Members of the European Parliament are threatening to reject the 2021-2027 EU budget if member states don’t make a clear commitment to introducing new EU-wide taxes to finance it.
To read more go here Subscription RequiredKenya's DST Could Force Out Digital Gaints
By: Mattias Cruz Cano
Multinational enterprises (MNEs) that are struggling to decipher Kenya’s vague digital services tax (DST) legislation may decide to exit the country instead of risking non-compliance
To read more go here Subscription RequiredIndonesia Defends Digital Tax Plans Against U.S. Investigation
By: Stephanie Soong Johnston
The Indonesian government intends to implement an electronic transaction tax that would take into account consensus on a global approach to modernize corporate tax rules, and remains “open to dialogue” about its plans.
To read more go here Subscription RequiredBEPS Initiatives May Hit Ireland Harder Than Expected
By: Kiarra M. Strocko
The OECD’s base erosion and profit-shifting initiatives and international tax changes may affect Irish corporate tax revenue over the medium term by more than the €2 billion previously estimated by Ireland's Department of Finance.
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