The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
By: Sarah Paez
A proposal for public country-by-country reporting is tied up in interinstitutional negotiations, where the European Parliament and EU Council have differing views on the scope of the proposal, according to an EP committee chair.
By: Stephanie Soong Johnston
Now that the Biden administration has proposed ways to revitalize global tax reform negotiations, chances are high that countries will be able to agree on a common way forward, the EU’s tax commissioner said.
By: Mindy Herzfeld
Mindy Herzfeld analyzes the different proposals to change the taxation of foreign earnings in the international tax rules, specifically the Biden administration’s proposal for imposing GILTI on a country-by-country basis.
By: Martin A. Sullivan
Martin Sullivan provides three policy justifications — contrary to the OECD and consistent with the Biden administration’s intentions — for repealing QBAI. He then offers a simple alternative to the QBAI approach for exempting routine returns as a possible compromise between the OECD and administration positions.
By: Mehreen Khan and Laura Noonan
Europe’s low-tax nations have responded positively to the Biden administration’s plans for a radical reform of global corporate taxation, even though they will lose out — but signalled that Washington can expect a fight over much of the detail.
By William Horobin, Catherine Bosley, and Jana Randow
A surprise U.S. drive to overhaul international corporate taxation promises a new era for governments to capture a bigger tax take from some of the most successful global businesses -- if only the rest of the world can agree.
By Laura Davison and Isabel Gottlieb
Multinational companies have long used creative -- and legal -- ways to shrink their tax bills. One is to book profits from customers in places like Boston and Berlin as if they came from, say, Bermuda, which has no corporate income tax. Long-stalled efforts to revamp the global tax system are getting a new push, thanks to the pandemic and a policy U-turn from the U.S. The complex proposals boil down to two basic notions: setting a minimum corporate tax rate across the world (think of this as making a bigger revenue pie), and rewriting the rules for allocating that revenue among countries (cutting the pie up differently).
By Isabel Gottlieb and Laura Davison
The Biden administration has floated a compromise proposal to counterparts around the world that would apply a new international tax code to, at most, 100 global corporate giants. The U.S. plan would consider a company’s profitability in determining whether more of its income should be taxed by the countries where it does business -- something the Biden administration argues will resolve long-standing disputes about which companies should be targeted by new global tax rules -- according to a document obtained by Bloomberg News.
By Michael Rapoport
An IRS proposal denying foreign tax credits for companies hit by digital taxes outside the U.S. is too broadly written, business groups warned. The 2020 proposed rules (REG-101657-20; RIN: 1545-BP70) would prevent companies from getting U.S. tax credits on many taxes on which they’ve historically been able to do so—such as withholding taxes—and could lead to double taxation, they told the IRS during a virtual hearing Wednesday.
By R. Mark Adams
As long as there are corporate taxes there will be arguments about what is fair, competitive and how to avoid a “race to the bottom” (“U.S. Aims for Global Minimum Corporate Tax Rate,” Page One, April 6). Alas, there is a simple solution: Set the rate at zero. Corporate taxes support only about 10% of federal receipts, a figure that could be easily covered by raising other taxes. Economists already debate whether corporations truly pay taxes or merely pass them along in an inefficient and, yes, unfair, manner. Clever ploys such as domicile shifting and inversions will be relegated to the scrapheap of corporate history. And if none of this works, well, deficit spending is all the rage anyway; there isn’t the slightest pretense of fiscal discipline anywhere near our nation’s capital.
Read More International Tax News