Americas

Africa

Is the US about to blow up the OECD’s compromise “pillar one” plan for taxing multinational group profit?

December 5, 2019

In a surprising development, US Treasury Secretary Stephen Mnuchin has revealed that the US no longer supports key elements of the OECD’s compromise proposal to overhaul the rules for allocating multinational group profit and related taxing. . .

Africa

OECD releases 186 comment letters on proposal for global minimum tax on multinational group profit

December 3, 2019

The OECD today released 186 comment letters in response to its request for assistance in the design of a global minimum tax on multinational group profit. The OECD also released the, , ,

Americas

US publishes final and proposed base erosion anti-abuse tax regs

December 3, 2019

The US on December 2 released 343 pages of final and proposed regulations on the base erosion and anti-abuse tax (BEAT). The BEAT, added in the . . .

Americas

US issues final foreign tax credit regulations

December 3, 2019

The US IRS on December 2 issued comprehensive final and temporary regulations addressing the foreign tax credit. The new regs finalize a . . .

Americas

EU Commission won’t challenge Starbuck’s State aid victory, Vestager says: Lewis Crofts and Nicholas Hirst / MLex Market Insight→

December 3, 2019

Americas

US trade officials propose tariffs of up to 100 percent on French goods to counter digital services tax

December 2, 2019

The office of the United States Trade Representative (USTR) today proposed retaliatory tariffs of up to 100 percent on French wine, cheese, handbags, makeup, china, and similar items, after concluding that France’s digital services tax . . .

Americas

US Ninth Circuit rejects request for hearing in key transfer pricing case

December 2, 2019

Sid Paruthi, CA, of Moss Adams, Campbell, California, discussses the November 11 decision of the US Court of Appeals for the Ninth Circuit panel which rejected the request for an en banc hearing in the Altera Corp v. Commissioner transfer pricing case . . .

Africa

Tax researcher disagrees with OECD’s Ben Dickenson, says developing countries should negotiate global tax rewrite as a block to even out power imbalance: Joy Ndubai / ICTD→

November 29, 2019

Americas

OECD releases reports assessing cross-border tax dispute resolution in seven countries

November 29, 2019

OECD, on November 28, released peer review reports assessing cross-border tax . . .

Africa

OECD celebrates Global Forum’s 10th anniversary

November 29, 2019

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI) in Manno, Switzerland discusses the 10th anniversary celebration of the OECD-led Global Forum on Transparency and Exchange of Information where more than 386 delegates from more than 142 jurisdictions met in Paris . . .

Americas

US IRS finalizes regulations on constructive ownership for controlled foreign corporation rules

November 19, 2019

The US IRS on November 19 published final regulations on the attribution . . .

Americas

New Japan, Peru tax treaty signed

November 19, 2019

Japan and Peru on November 18 signed a tax treaty, the Ministry of Foreign Affairs . . .

Americas

OECD’s digital tax plan would raise little revenue for France, Germany, US, and China, French Council of Economic Analysis concludes: Financial Times→

November 19, 2019

Africa

BRICS countries look forward to further progress on two-pillar approach to address digitalization: BRICS Information Centre→

November 18, 2019

Americas

OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes

November 18, 2019

The OECD today requested input from taxpayers to assist in an assessment of the timeliness and efficiency of the cross-border tax dispute resolution process in Aruba, Bahrain, Barbados,. . .

Algeria

Costa Rica issues new transfer priccing documentation guidelines: KPMG→

November 15, 2019

Americas

US Tax Court resolves Eaton’s transfer pricing dispute

November 14, 2019

Elisa Kaminsky of BaseFirma, Miami, discusses the October 28 US Tax Court decision in Eaton, concerning the IRS’s cancellation of an advance pricing agreement . . .

Americas

United States: OMB review completed for final BEAT regs: KPMG→

November 12, 2019

Americas

First Look: Ninth Circuit denies rehearing in Altera

November 12, 2019

The United States Court of Appeals for the Ninth Circuit today denied a rehearing en banc in . . .

EU Council addresses VAT for e-commerce, excise tax, tax blacklist, digital tax

November 12, 2019

MNE Tax Contributing Editor, Davide Anghileri, of the University of Lausanne, discusses political agreements reached by the European Council during its meeting of November 8 that are related to taxation . . .

Americas

Dominican Republic budget proposes new tax on digital services

November 11, 2019

The Dominican Republic on September 26 issued its budget for fiscal year 2020, proposing new taxes on companies that operate through a digital platform, such as Netflix, Spotify, Airbnb, well as the implementation of country-by-country reporting on large multinationals, writes Elisa Kaminsky, BaseFirma, Miami . . .

Americas

EU Code of Conduct Group proposes changes to tax blacklist

November 7, 2019

Davide Anghileri, University of Lausanne, Switzerland discusses the EU Code of Conduct Group’s November 4 recommendations for changes to the EU tax blacklist . ..

Americas

US IRS large business/international unit adds new compliance campaign targeting cross-border activity

November 6, 2019

The US IRS’s Large Business and International (LB&I) division on November 4 announced . . .

Americas

US, Singapore negotiating exchange of country-by-country reporting data

November 4, 2019

The US Treasury on October 31 announced that the US and Singapore are . . .

Americas

Proposed regs would significantly restrict use of tax losses in US and international M&A transactions

October 31, 2019

Frank J. Vari, Practice Leader, at FJV Tax Consulting, Boston, Massachusetts, discusses recently released US proposed IRC §382 regulations which would dramatically reduce an acquiring corporation’s ability to use a target’s built-in losses, US net operating loss (NOL) carryforwards, and similar tax attributes following a substantial change in ownership . . .

Americas

Ukrainian Parliament ratifies FATCA agreement with US: 112 UA→

October 31, 2019

Americas

Brazil guidance addresses taxation of amounts paid under “cost-sharing” agreements

October 30, 2019

Francisco Lisboa Moreira, Tax Partner at Bocater Advogados, São Paulo, discusses important Brazil’s Federal Revenue Service guidance, issued October 2, on the tax treatment of amounts paid under a cost-sharing agreement between related group companies . . .

Americas

US House passes bipartisan bill requiring companies to report ownership to federal government but exempts large or publicly traded companies: Steve Wamhoff / Fact Coalition→

October 29, 2019

Americas

US’s LB&I should change its approach to the selection of audit campaign issues, oversight agency says: Treasury Inspector General for Tax Administration→

October 28, 2019

Americas

BVI releases final rules on economic substance: British Virgin Islands International Tax Authority→

October 28, 2019

Africa

OECD’s Pillar One proposal could be first step toward shift in taxing rights to destination countries: Michael Devereux / University of Oxford→

October 23, 2019

Americas

US, Armenia FATCA agreement enters into force

October 23, 2019

US Treasury has announced on its website . . .

Africa

Estimating reliable transfer pricing profit indicators requires use of all available data

October 23, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that the arm’s length argument of many transfer pricing reports is weak because the sample is not random and the sample size of three-year data points is too small . . .

Americas

Peru tax authority guidance addresses deductibility of interest paid to non-residents

October 19, 2019

Elisa Kaminsky, of BaseFirma, Miami, discusses September 20 guidance issued by the Peruvian tax authority on the treatment for interest expenses on foreign debt . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Americas

US could still retaliate in response to French digital tax despite earlier suggestions of compromise: Bloomberg Tax→

October 17, 2019

Americas

US IRS addresses expiration of temporary section 385 debt/equity regs

October 13, 2019

The US IRS on October 11 released IRS guidance addressing the expiration of debt-equity documentation . . .

Americas

Cayman Islands to introduce public register of beneficial ownership: Cayman Islands→

October 11, 2019

Americas

Bipartisan US Senate bill would require reporting on beneficial ownership information: Joseph Moreno / Cadwalader Cabinet→

October 11, 2019

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