The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Archives: May 2021Subscribe
By William Horobin
European governments are increasingly optimistic that the G-7 could mark a breakthrough after U.S. President Joe Biden’s administration made proposals on the two pillars of the talks: where to tax firms in the digital era, and a minimum rate. Le Maire said that while the U.S. proposal for a 15% floor would feature in the London talks, the key issue for France remains new rules on how to divide up rights to tax multinationals -- the so-called pillar one of international negotiations. On Wednesday, he said that, subsequent to a recent U.S. proposal to limit rules to the 100 biggest firms, there is progress toward ensuring digital giants are covered.
By Tim Ross, Alessandra Migliaccio, and William Horobin
A global agreement that could reshape the tax landscape for the biggest corporations is approaching a crucial first stage as the Group of Seven nations hone in on an accord that might feature both a minimum rate and encompass digital giants. If finance ministers due to meet virtually on Friday and in person next week can find enough common ground, that could pave the way for a wider consensus to form within the Group of 20, building a foundation for the worldwide agreement that is in negotiators’ sights.
By Birgit Jennen and William Horobin
Germany and France said discussions on a global agreement on corporate tax rates were entering the home stretch and that a deal could be reached within weeks. French Finance Minister Bruno Le Maire indicated support for a U.S. proposal to set the minimum rate at 15%, calling it an “interesting and solid basis” for discussion.
By Hamza Ali
The EU’s digital levy will be broadly based so as not to discriminate against U.S. tech firms, a top European Commission tax official said Tuesday. The governments of France, Spain, and Italy, among others, have unilaterally acted to create their own digital services taxes. That drew the ire of the Trump administration, which argued that they unfairly targeted U.S. tech firms because of their high thresholds for earnings. It opened trade investigations to determine whether they justified the imposition of retaliatory tariffs. Angel said that the EU’s tax would show that concerns that the new digital levy would be similar to these taxes are misplaced.
By Isabel Gottlieb
The Organization for Economic Cooperation and Development’s two-part plan would see more corporate profits attributed to the countries where companies make sales, known as “Pillar One,” and establish a global minimum corporate tax rate, known as “Pillar Two.” The U.S. in April pitched a proposal that would narrow the OECD plan and target 100 of the largest and most profitable companies. Crapo called for Treasury to report to Congress on how many U.S. companies would be among the roughly 100 firms that would see their profits reallocated under the U.S. Pillar One proposal, and how the plan would affect U.S. tax revenue.
By William Horobin
French Finance Minister says U.S. proposal for a global minimum tax on corporations of 15% is a “good compromise,” but the key question is clearly to have a compromise and agreement about the two pillars: digital taxation and minimum taxation.” Le Maire says there must be a political agreement on both elements of international tax negotiations by the G-20 meeting in July at the latest.
By: Andrew Velarde
Green book provides more detail on Biden administration’s GILTI and SHIELD proposals.
By: Emily L. Foster
Green book provides more detail on Biden administration’s minimum book tax proposal.
By: Stephanie Soong Johnston
The Senate’s top Republican taxwriter, Senate Finance Committee ranking member Mike Crapo, R-Idaho, has asked Treasury for further analysis about its position in OECD-led tax reform negotiations — and for a promise that any deal emerging from those talks won’t discriminate against American companies.
By: Lee A. Sheppard
Lee Sheppard analyzes the General Court of the European Union (GCEU)’s recent decision in Engie, which she argues treated an affiliated group as a single taxpayer, and applied the step transaction doctrine on the basis of substance rather than form.
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