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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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International Tax News Blog

Archives: April 2020

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  • IRS Relaxes Tax Residency Requirements Amid COVID-19 Pandemic

    By: Kiarra M. Strocko

    A nonresident who is temporarily present in the United States for up to 60 consecutive calendar days because of COVID-19 travel disruptions will not be considered a U.S. resident under the IRS’s substantial presence test.

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    By Kiarra M. Strocko, posted on Wednesday April 22, 2020
  • Firms Ask EU for Delay of Cross-Border Tax Arrangement Reporting

    By: Sarah Paez

    Financial associations are asking the European Commission to extend the deadline for implementation of requirements for intermediaries to report cross-border tax arrangements that promote avoidance until 2021 because of complications from the coronavirus.

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    By Sarah Paez, posted on Wednesday April 22, 2020
  • Business Groups Urge OECD, EU to Address Tax Relief Roadblocks

    By: Annagabriella Colon

    Twelve business groups have asked the OECD and the European Commission to remove obstacles to withholding tax relief on cross-border portfolio investments that have arisen as a result of the COVID-19 pandemic.

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    By Annagabriella Colon, posted on Wednesday April 22, 2020
  • Global Tax Reform Project Should Consider COVID-19, ICC Says

    By: Stephanie Soong Johnston

    The OECD should take into account the coronavirus pandemic’s effects on businesses as it continues to work on updating the global corporate tax rules for the digital age, a major trade group said.

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    By Stephanie Soong Johnston, posted on Thursday April 23, 2020
  • Tax Optimism for a Post-Pandemic World

    By: Mindy Herzfeld

    Mindy Herzfeld questions whether the economic crisis caused by the coronavirus pandemic could lead to beneficial changes for the international tax system.

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    By Mindy Herzfeld, posted on Monday April 27, 2020
  • Navigating New Foreign Income Tax Allocation and Apportionment Regs

    By: Carrie Brandon Elliot

    Carrie Elliot reviews new proposed regs that allocate taxes to income categories in order to calculate the foreign tax credit limitation.

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    By Carrie Brandon Elliot, posted on Monday April 27, 2020
  • The Impact of the COVID-19 Pandemic on Tax Residence Rules

    By: Michael J.A. Karlin

    In this article, the author examines the definition of a resident alien under section 7701(b) in the context of the coronavirus pandemic.

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    By Michael J.A. Karlin, posted on Monday April 27, 2020
  • Practical Transfer Pricing in Uncertain Economic Conditions

    By: Robin Hart

    In this article, the author discusses how to reevaluate transfer prices based on market conditions caused by COVID-19 and mitigate complexities associated with year-end processes. He also examines how (re)structuring intercompany transactions with high upfront payments can be effective in deploying cash within a multinational group.

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    By Robin Hart, posted on Monday April 27, 2020
  • International Tax Review logo

    Companies must align local and global tax functions for CbCR audits

    By Josh White

    Country-by-country reporting (CbCR) has pushed Indian taxpayers to seek out greater alignment between the local tax function and the global tax team.

    By Josh White, posted on Thursday April 16, 2020
  • Addressing Challenges in the Hard-to-Value Intangibles Guideline

    By: Andrew Hughes

    In this article, the author uses a Monte Carlo simulation approach to valuing hard-to-value intangibles, discusses the use of publicly available data in considering all known possibilities in performing a simulation, and walks practitioners through the challenges of implementing that kind of model.

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    By Andrew Hughes, posted on Friday April 17, 2020


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