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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Much like a smartphone in need of an operating system update to keep up with security threats and repair glitches, the international tax system may need some fixes to address the tax challenges of the digital economy. And, if the debate in 2018 is any indication, governments appear to be getting close to some agreement on the best way forward.
By Stephanie Soong Johnston
Because Finnish law incorporates the OECD transfer pricing guidelines effective during the tax year, the tax administration cannot use profit splits for pre-2010 years unless the transactions are too closely interrelated to be priced independently.
By Ryan Finley
The Israel Tax Authority (ITA) has issued letters informing companies they must amend prior tax returns to comply with a Supreme Court decision earlier in the year on the taxability of employee stock options.
By William Hoke
EU member states have reached political agreement on granting the European Banking Authority (EBA) new powers to fight money laundering.
By Elodie Lamer
In this article, the author describes what he calls the emergence of an international tax “war” and provides an overview of global digital taxation reform efforts. He argues that the global digital tax conflict masks a growing dissatisfaction with how to tax value associated with global transactions.
By Arthur J. Cockfield
In this article, the author examines a proposal to tax digital services in Mexico, contemplating both its efficacy and its wisdom, and considers whether existing mechanisms within the country’s tax system could effectively tax the digital economy, at least until there is a multilateral solution in place.
By Koen van ’t Hek
The American Institute of CPAs has suggested that taxpayers be able to exclude the amount of deemed foreign taxes paid in the inclusion year of the transition tax under section 965 (generally 2017) from the calculation of the 150 percent special rule for controlled foreign corporations in Rev. Proc. 2015-13 to prevent the unintended denial of audit protection under that guidance.
By Tax Analysts
By Isabel Gottlieb
The world’s biggest companies will find it harder in 2019 to set up some business structures that let them achieve the lowest tax rates, after a novel new multilateral treaty goes into effect.
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