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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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Archives: August 2020
SubscribeEconomic Analysis: New Data Show So Far No Post-TCJA Profit Shifting to U.S.
By: Martin A. Sullivan
In economic analysis, Martin A. Sullivan says that new data show little change in profit shifting by multinational corporations since enactment of the Tax Cuts and Jobs Act, but that it's still early.
To read more go here Subscription RequiredU.K. Denies Government U-Turn on Digital Services Tax
By: Stephanie Soong Johnston
HM Treasury has denied a U.K. media report that the U.K. government is considering abolishing the digital services tax, partly because of U.K.-U.S. trade concerns as both countries continue negotiating a deal.
To read more go here Subscription RequiredFacebook France to Pay €106 Million in Back Taxes
By: Sarah Paez
Facebook’s French subsidiary has agreed to pay over €100 million in back taxes to French tax authorities after an audit found the company had not paid the correct amount of taxes for nearly a decade.
To read more go here Subscription RequiredDraft U.N. Article to Tax Digital Services May See Wide Adoption
By: Stephanie Soong Johnston
If a new draft article to tax digital services is added to the U.N. model tax convention, it’s likely it will then be included in several existing and future tax treaties, an Indian official said.
To read more go here Subscription RequiredOECD Pillar 2 Draft Further Maps Out GLOBE Minimum Tax Proposal
By: Stephanie Soong Johnston and Ryan Finley
An OECD draft report on its global anti-base-erosion (GLOBE) proposal charts out significant design progress but has yet to address how it will coexist with the U.S. global intangible low-taxed income provision.
To read more go here Subscription RequiredTop Brazilian Lawmaker Pans ‘Digital’ Financial Transactions Tax
By: William Hoke
The speaker of Brazil’s Chamber of Deputies voiced opposition to the government’s plans for a “digital” tax on financial transactions because of its potential similarity to a lapsed financial transactions tax that was widely criticized.
To read more go here Subscription RequiredMasterCard Escapes Equalization Levy for Now, India Court Says
By: Stephanie Soong Johnston
MasterCard won’t have to pay an equalization levy in India because it already has a permanent establishment there, but its liability may change depending on the outcome of its appeal in a separate court case.
To read more go here Subscription RequiredDutch Exit Tax Gains Support but Could Threaten Business Climate
By: Sarah Paez
A Dutch bill that would impose a conditional exit tax on reorganizations like company transfers and mergers may face legal troubles and have unintended consequences for the business climate.
To read more go here Subscription RequiredWhy the United Nations Digital Tax Proposal Deserves More Attention
By: Nana Ama Sarfo
Nana Ama Sarfo looks at the U.N.'s new digital services treaty proposal, how it serves the interests of developing countries, and how it diverges from the OECD's approach.
To read more go here Subscription RequiredThe GILTI High-Tax Exception: Who Benefits?
By: Mindy Herzfeld
Mindy Herzfeld examines whether, in finalizing regulations implementing the subpart F high-tax exception to items of income that would otherwise be tested income taxable as global intangible low-taxed income, Treasury exceeded its statutory authority, subverted congressional intent, and provided a giveaway to corporate taxpayers.
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