The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Archives: February 2021Subscribe
By Richard Rubin and Theo Francis
Richard Rubin and Theo Francis consider how tax court decisions may impact companies’ bottom lines, or not.
By Alexander Osipovich
Rep. Rashida Tlaib (D., Mich.), a member of the so-called “squad” of firebrand progressives in the House, is calling for a financial transaction tax to rein in risky stock trading and to redistribute wealth. “The majority of Americans support taxing Wall Street transactions,” she said at Thursday’s hearing on the GameStop trading frenzy. “This tax, to me, would discourage risky and high-frequency trading.”
By Reuven S. Avi-Yonah and Gianluca Mazzoni
Coca Cola v. Commissioner (Tax Court, Nov. 18, 2020) is the first decisive IRS victory in a major transfer pricing case since 1979. If the outcome is not reversed on appeal, this will mark an important shift in transfer pricing litigation in the US, and perhaps indicate that the IRS could win some of the other major pending cases, like the one against Facebook.
By Reuven S. Avi-Yonah
This article will argue that we should tax corporations for the same reason we originally adopted the corporate tax in 1909: to limit the power and regulate the behavior of our largest corporations, which are monopolies or quasi-monopolies that dominate their respective fields and drive their competitors out of business (the best example being Big Tech — that is, Amazon, Apple, Facebook, Google, and Microsoft). But if that is the reason to have a corporate tax, it should have a different structure from the current flat corporate tax of 21 percent. Instead, the tax should be set at zero for normal returns by allowing the expensing of physical capital, but at a sharply progressive rate for supernormal returns (rents).
By Stephen Gardner
The European Parliament plans to warn international tax negotiators that a mid-2021 deadline for agreement on digital and minimum corporate taxation must be respected, lawmakers said. The warning that the European Union is “not accepting any more a delay” would take the form of a nonbinding resolution that the Parliament would finalize in April, said Martin Hlavacek, a centrist member from the Czech Republic, who is one of the drafters of the resolution. He was speaking during a tax subcommittee meeting Wednesday.
By Colin Wilhelm
The U.S. is committed to engaging in multilateral tax talks at the OECD and G20, Adewale Adeyemo, nominee to be deputy Treasury secretary, told members of the Senate Tuesday.
By Isabel Gottlieb
Congress would be “leaving money on the table” if the rest of the world agreed to the OECD’s digital tax plan without the U.S., a former Treasury official said. Even if the U.S. didn’t sign on, its large companies would likely still face the effects of the OECD’s proposed “Amount A,” said Lafayette “Chip” Harter, who served as deputy assistant Treasury secretary for international tax affairs until late last year.
By Alex Morales
The U.K. expects to keep business levies competitive with the other Group of Seven nations, a government official familiar with the matter said, giving Chancellor of the Exchequer Rishi Sunak scope to raise corporation tax in his budget next week. The U.K. rate is already the lowest among the seven nations at 19%, the person said. Rates in Canada, France, Germany, Italy and Japan are all above 25%. The official also pointed to proposals earlier this week by Treasury Secretary Janet Yellen to lift the U.S. rate to 28% from 21%.
By: Stephanie Soong Johnston
Multinational enterprise groups can apply to participate in a new multilateral tax risk assessment and assurance program spearheaded by the OECD Forum on Tax Administration (FTA) to obtain greater certainty about cross-border tax risks.
By: Tatiana Falcão
In this article, the author explains how Brazil’s transfer pricing methods, which rely heavily on fixed margins, can be reconciled with the OECD’s transfer pricing guidelines and how emerging economies can benefit from the resulting system.
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