The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Archives: April 2020Subscribe
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.
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.
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.
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.
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.
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.
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.
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: 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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