Americas

BVI economic substance and beneficial ownership reporting portal goes live: Virgin Islands International Tax Authority→

July 1, 2020

Americas

US tax icon Ed Kleinbard dies after decades of public service, tax scholarship: Paul Caron / TaxProf Blog→

June 30, 2020

Africa

Gilead’s COVID-19 drug remdesivir: the transfer pricing implications

June 29, 2020

Economist Dr. J. Harold McClure, New York, NY, discusses likely transfer pricing issues associated with Gilead Sciences’ COVID-19 therapy, remdesivir, comparing the transfer pricing treatment of Gilead Sciences’ blockbuster HIV and hepatitis C virus drugs . . .

Americas

US Senators Durbin and Doggett introduce bill to prevent inverted US companies from benefiting from federal COVID-19 assistance: Senator Dick Durbin→

June 25, 2020

Americas

Canada-Madagascar tax treaty enters into force: Government of Canada→

June 24, 2020

Americas

US Supreme Court lets Altera decision stand: implications for cost sharing and stock options

June 23, 2020

New York economist, Dr. J. Harold McClure, discusses the implications of the US Supreme Court’s June 22 announcement that it would not review the Ninth Circuit panel decision in Altera . . .

Africa

The OECD’s “no Plan B” approach on digital taxation backfires

June 22, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, discusses the breakdown of global digital tax talks and the likely future of negotiations . . .

Americas

OECD-led rewrite of international tax rules should not be rushed given COVID-19, US tax-writing lawmakers say: The United States Senate Committee on Finance→

June 19, 2020

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Americas

US has abandoned negotiations with EU on digital tax, proposes pausing OECD-led negotiations, US officials say: Andrea Shalal / Reuters→

June 17, 2020

Africa

Transfer prices based on EBITDA, not EBIT

June 17, 2020

Dr. Ednaldo Silva, Founder & Director at RoyaltyStat, discusses whether transfer pricing analysis of operating profits should be based on EBITDA or EBIT . . .

Americas

Mexico proposal would temporarily reduce VAT from 16 percent to 10 percent: KPMG→

June 16, 2020

Americas

The Puma Nordic and Columbia Sportswear transfer pricing cases and the limits of the TNMM

June 15, 2020

Dr. Harold McClure, a New York economist, analyzes a recent Swedish transfer pricing case, Puma Nordic, and a 2015 Indiana transfer pricing case, Columbia Sportswear, where the transactional net margin method (TNMM) was applied to determine the return of a distribution affiliate . . .

Americas

US IRS solicits input for priority guidance plan

June 12, 2020

The US IRS has, in Notice 2020-47, invited the public to submit recommendations. . .

Americas

OECD’s Gurría warns of trade wars should digital tax deal fail: BBC News→

June 12, 2020

Americas

US continues to block digital tax agreement, French minister says: Isabel Gottlieb / Bloomberg Tax→

June 12, 2020

Americas

US, Curacao agree to exchange country-by-country tax reports on large multinational groups

June 12, 2020

US Treasury this week announced that the US and Curacao have signed a competent authority agreement . . .

Taxing offshore indirect transfers, the Platform’s new toolkit

June 10, 2020

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland writes about the Platform for Collaboration on Tax’s June 4 toolkit on taxation of offshore indirect transfers . . .

Americas

Professor advocates worldwide digital tax based on country-specific income thresholds but subject to a worldwide de minimis amount: Assaf Harpaz / SSRN→

June 8, 2020

Americas

Mexico SAT settles nine large MNE’s pre-2019 tax bills, seeks additional tax from six more MNEs, to audit law firms promoting aggressive structures: The Yucatan Times→

June 3, 2020

Americas

Whirlpool’s maquiladora: the Mexican transfer pricing perspective

June 3, 2020

Dr. Harold McClure, a New York economist, discusses transfer pricing issues with respect to Whirlpool’s Mexico affiliate, which conducted toll manufacturing operations on behalf of a Luxembourg affiliate, as described in the recent Tax Court case, Whirlpool Financial Corporation v. Comr. . . .

Americas

Spain says digital tax uses objective criteria, won’t discriminate against US MNEs: Reuters→

June 3, 2020

Americas

Mexico issues tax rules on withholding by digital service providers, online platforms

June 2, 2020

Arturo Treviño Villarreal, a tax partner with Fratelli Consultores, Monterrey, Mexico, discusses new rules published by Mexico’s tax authorities on May 12 that provide additional guidance on the taxation in Mexico of digital services and transactions performed on technological platforms . . .

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Americas

Canada addresses COVID-19 travel restrictions’ effect on tax residency, PEs: KPMG→

May 27, 2020

Americas

US IRS relaxes rules on dual consolidated loss, Form 8858 filing in response to COVID-19 travel disruption

May 27, 2020

The US IRS this week announced that in some cases where individuals temporarily conduct . . .

Africa

Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches

May 26, 2020

Hugo Chary and Thibaut Roques of TP qube, Paris / Bordeaux, France, discuss how to adjust comparable company searches to reflect the new market conditions that have arisen from the COVID-19 crisis . . .

Americas

IRS corrects foreign tax credit regs: Internal Revenue Service→

May 21, 2020

Africa

Countries still can’t agree on update to multinational group taxation rules, OECD official says

May 21, 2020

The 137 countries that make up the “Inclusive Framework on BEPS” are having a difficult time reaching agreement on an update to the global rules for allocating multinational group profits among nations, according to Pascal Saint-Amans, OECD Center for Tax Policy and Administration. Saint-Amans warned. . .

Costa Rica

Americas

US IRS assisting taxpayers with APAs during downturn, relaxes APA and MAP filing requirements

May 13, 2020

The US IRS has advised that it is willing to assist taxpayers that have executed an advance . . .

Americas

Professor says US should impose excess profits tax on companies that profit greatly from coronavirus: Reuven S. Avi-Yonah / SSRN→

May 12, 2020

Americas

US professor predicts impact of COVID-19 on short and long term US tax policy: Reuven S. Avi-Yonah / SSRN→

May 8, 2020

Americas

Brazil proposes new digital tax on revenue

May 6, 2020

Francisco Lisboa Moreira, a tax partner with Bocater Advogados, Brazil, discusses a proposal for a Brazilan digital tax introduced to the House of Representatives on May 4 . . .

Americas

Lawmaker introduces bill to treat investment in US territories as domestic rather than foreign under GILTI rules: Stacey E. Plaskett (D-USVI)→

May 6, 2020

Americas

US IRS corrects PFIC regs: Federal Register→

May 6, 2020

Americas

Colombia officially joins OECD as 37th member: Modern Diplomacy→

May 4, 2020

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin

Americas

BVI economic substance and beneficial ownership reporting portal goes live: Virgin Islands International Tax Authority→

US tax icon Ed Kleinbard dies after decades of public service, tax scholarship: Paul Caron / TaxProf Blog→

Gilead’s COVID-19 drug remdesivir: the transfer pricing implications

US Senators Durbin and Doggett introduce bill to prevent inverted US companies from benefiting from federal COVID-19 assistance: Senator Dick Durbin→

Canada-Madagascar tax treaty enters into force: Government of Canada→

US Supreme Court lets Altera decision stand: implications for cost sharing and stock options

The OECD’s “no Plan B” approach on digital taxation backfires

OECD-led rewrite of international tax rules should not be rushed given COVID-19, US tax-writing lawmakers say: The United States Senate Committee on Finance→

OECD to stick to digital tax negotiation timetable despite US opposition

US has abandoned negotiations with EU on digital tax, proposes pausing OECD-led negotiations, US officials say: Andrea Shalal / Reuters→

Transfer prices based on EBITDA, not EBIT

Mexico proposal would temporarily reduce VAT from 16 percent to 10 percent: KPMG→

The Puma Nordic and Columbia Sportswear transfer pricing cases and the limits of the TNMM

US IRS solicits input for priority guidance plan

OECD’s Gurría warns of trade wars should digital tax deal fail: BBC News→

US continues to block digital tax agreement, French minister says: Isabel Gottlieb / Bloomberg Tax→

US, Curacao agree to exchange country-by-country tax reports on large multinational groups

Taxing offshore indirect transfers, the Platform’s new toolkit

Professor advocates worldwide digital tax based on country-specific income thresholds but subject to a worldwide de minimis amount: Assaf Harpaz / SSRN→

Mexico SAT settles nine large MNE’s pre-2019 tax bills, seeks additional tax from six more MNEs, to audit law firms promoting aggressive structures: The Yucatan Times→

Whirlpool’s maquiladora: the Mexican transfer pricing perspective

Spain says digital tax uses objective criteria, won’t discriminate against US MNEs: Reuters→

Mexico issues tax rules on withholding by digital service providers, online platforms

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

Canada addresses COVID-19 travel restrictions’ effect on tax residency, PEs: KPMG→

US IRS relaxes rules on dual consolidated loss, Form 8858 filing in response to COVID-19 travel disruption

Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches

IRS corrects foreign tax credit regs: Internal Revenue Service→

Countries still can’t agree on update to multinational group taxation rules, OECD official says

OECD invites Costa Rica to join as 38th member: OECD→

US and lawmakers and officials to propose tax breaks to encourage companies to move operations out of China: Reuters→

US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure

US IRS assisting taxpayers with APAs during downturn, relaxes APA and MAP filing requirements

Professor says US should impose excess profits tax on companies that profit greatly from coronavirus: Reuven S. Avi-Yonah / SSRN→

US professor predicts impact of COVID-19 on short and long term US tax policy: Reuven S. Avi-Yonah / SSRN→

Brazil proposes new digital tax on revenue

Lawmaker introduces bill to treat investment in US territories as domestic rather than foreign under GILTI rules: Stacey E. Plaskett (D-USVI)→

US IRS corrects PFIC regs: Federal Register→

Colombia officially joins OECD as 37th member: Modern Diplomacy→