Americas

Barbados becomes 133rd country to join global tax agreement, holdouts dwindle to six

August 13, 2021

The agreement on international tax reform that was endorsed by the majority of the 139 “Inclusive Framework” countries on July 1 grew one country stronger on August 12 as Barbados became the latest . . .

Americas

Singapore guidance on intercompany financing: two illustrations

August 13, 2021

New York City Economist Dr. J. Harold McClure analyzes two examples the Inland Revenue Authority of Singapore (IRAS) provided on August 10 in the sixth edition of its e-tax transfer pricing guidance, extending its coverage of . . .

Americas

British Virgin Islands Finance panel suggests global minimum tax will not necessarily upend jurisdiction’s zero-tax rate nor dramatically impact types of businesses that locate there: Claire Shefchik / BVI Beacon→

August 13, 2021

Accounting

US IRS updates accounting method rules for taxable year of inclusion, credit card fees

August 12, 2021

On August 12, the US Internal Revenue Service outlined procedures (Revenue Procedure 2021-34) for obtaining automatic consent to change methods of accounting to comply with final rules issued in 2020 under Internal Revenue Code Section 451 relating to the taxable year of . . .

Americas

US foreign-derived intangible income (FDII) deduction may be imperfect, but Congress should not repeal without evaluating how doing so could incentivize US companies to move intellectual property assets overseas: Daniel Bunn / Tax Foundation→

August 11, 2021

Americas

US bill proposing tax on corporate book income could undermine R&D incentives

August 11, 2021

A bill announced by US Senator Elizabeth Warren (D-Mass.) on August 9 would impose a tax on the income that large corporations report to their shareholders with an aim to prevent those corporations from using “loopholes” – including tax incentives, like the research and development (R&D) tax credit . . .

Americas

US infrastructure bills clear hurdles, still waiting on corporate tax provisions

August 11, 2021

The US Senate on August 10 approved President Biden’s USD 1 trillion bipartisan traditional infrastructure bill, while on August 11 Senate Democrats adopted the framework for a USD 3.5 trillion partisan “human infrastructure” budget bill. Neither bill, as yet, includes corporate tax measures . . .

Americas

Brazil’s upcoming tax reform will impact inbound investors

August 10, 2021

Luis Felipe de Campos, Rolim, Viotti, Goulart, Cardoso Advogados, discusses the substitute tax reform bill that Brazil’s Ministry of Economy presented to Congress on June 25, including provisions affecting corporate tax rates, profit distributions, interest . . .

Americas

Colombian tax reform proposes corporate rate increase, tax avoidance measures

August 10, 2021

María Helena Padilla, Pinilla, González y Prieto Abogados, discusses the Colombian government’s introduction of a tax reform bill on July 20 that includes an increase in the corporate tax rate, new measures to . . .

Americas

US Congress should take up international tax reform without waiting for OECD talks to conclude, because US can benefit from changes regardless of global deal and acting first will strengthen US negotiating position: The FACT Coalition→

August 9, 2021

Americas

Panama Papers: Luxembourg court confirms tax agency’s authority to request information from lawyers

August 6, 2021

Rafael Rivera, Managing Partner and Tax & Legal Partner at BDO Panama, discusses the Luxembourg High Administrative Court’s July 13 decisions – pertaining to the so-called “Panama Papers” cases – that overruled a lower court and held that the tax administration . . .

Africa

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

August 5, 2021

An update on reviews of preferential tax regimes published by the OECD on August 5 states that the US foreign-derived intangible income (FDII) regime is “in the process of being eliminated.” The new report includes updated conclusions with respect to 18 designated . . .

Americas

US IRS ‘practice unit’ outlines agency process for applying penalty for failure to include reportable transaction information with tax return: Internal Revenue Service→

August 4, 2021

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Americas

US, UK competent authorities address tax treaty’s limitation-on-benefits article

July 28, 2021

The US Internal Revenue Service on July 28 published two competent authority arrangements between the US and the UK that clarify the application of the limitation on benefits article in light of the UK’s exit from the EU (Brexit) and the entry into force of the US–Mexico–Canada Agreement (USMCA).

Accounting

US IRS explains tax rules for MNE branch income in a foreign currency

July 28, 2021

A practice unit published by the US Internal Revenue Service on July 26 describes the rules applicable to US multinational enterprises that enter into foreign currency transactions through . . .

Americas

US bill would create tax credit for US companies investing in Puerto Rico and other US territories to offset impact of global intangible low-taxed income (GILTI) provisions: Laura Weiss / Roll Call→

July 28, 2021

Americas

Global minimum tax could create confusion with current CFC rules

July 28, 2021

Thomas Locher, Tax Foundation’s Center for Global Tax Policy, discusses how the implementation of a global minimum tax could create confusion with current CFC rules, raising questions about . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Americas

EU continues to wrangle over global minimum tax’s carve-outs, rate

July 26, 2021

A July 21 study from the EU Tax Observatory predicts that a substance carve-out under the agreement for a proposed global minimum tax could exacerbate tax competition and would reduce by 15% to 30% the tax revenues that the EU would otherwise . . .

Accounting

FASB updates accounting standard for leases

July 23, 2021

A July 19 US accounting standards update from the Financial Accounting Standards Board (FASB) revises guidance related to a lessor’s accounting for certain leases with . . .

United States

US bill introduced to establish border carbon adjustment that would impose fee on carbon-intensive imports to account for costs US businesses incur in complying with environmental standards: Senator Chris Coons (D-Del.)→

July 22, 2021

Americas

US IRS advises on transfer pricing adjustments for Altera-related ‘reverse claw-backs’

July 21, 2021

A US Internal Revenue Service Office of Chief Counsel memorandum published on July 16 offers taxpayer advice with respect to transfer pricing issues related to cost sharing agreements containing “reverse claw-back” provisions, which operate . . .

Americas

Ireland seeks input on OECD tax proposals’ impact on Irish tax policy

July 20, 2021

The Irish Department of Finance on July 20 opened a consultation on implications for Ireland’s corporate tax policy arising from the two-pillar proposal for overhauling the international tax framework recently . . .

Americas

Chilean guidance addresses enhanced foreign tax credit rules under 2020 tax reform

July 20, 2021

Tomás Kovacevic, Barros y Errázuriz Abogados, discusses the Chilean tax agency’s May 19 clarification of the amended foreign tax credit rules enacted in Chile’s 2020 tax reform through guidance issued . . .

Americas

Brazilian tax reform’s second phase includes corporate, investment proposals

July 20, 2021

Carolina Becman and Kassia Paulo, Gaia Silva Gaede Advogados, discuss the Brazilian government’s June 25 presentation of the second phase of its proposed tax reform, which aims to change the income tax legislation for individuals and legal entities, as well as establish . . .

Americas

Nike’s transfer pricing state aid dispute: the underlying issues

July 19, 2021

New York City Economist Dr. J. Harold McClure analyzes the issues underlying the transfer pricing dispute involving Nike, following the General Court of the European Union’s July 14 ruling declining to annul the European Commission’s state aid investigation regarding . . .

Americas

Mexico’s outsourcing schemes’ demise and its tax and transfer pricing effects

July 19, 2021

Jesús Aldrin Rojas, Managing Partner at QCG Transfer Pricing Practice, discusses tax and transfer pricing considerations for business groups in Mexico following the country’s reform to various tax and labor laws to prohibit outsourcing of personnel, published in the official gazette on April 23 . . .

OECD

US nonpartisan agency’s review of Pillars 1 & 2 reports US companies may prefer Pillar 1 adoption to alternative of digital services taxes, while Pillar 2 would allow for more government tax revenues: Congressional Research Service→

July 16, 2021

OECD

Yellen predicts US businesses will press Congress to approve global corporate tax overhaul plans because of the tax certainty such an agreement would offer: Christopher Condon / Accounting Today→

July 14, 2021

Americas

Latin America tax transparency report finds region committed to tackling tax evasion through implementing tax information exchange standards, but the tools are not yet widely used: OECD→

July 13, 2021

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Accounting

US IRS explains steps to adjust for tax R&D costs reported in financial statements

July 9, 2021

A practice unit issued by the US Internal Revenue Service on July 7 walks through the steps for large business & international (LB&I) taxpayers to adjust research and development (R&D) expenses reported in . . .

Americas

US Republican lawmakers send Treasury Secretary Yellen letter pressing for harder stance in favor of pro-US terms in international tax negotiations: Senator Mike Crapo (R-Idaho) and Congressman Kevin Brady (R-Texas)→

July 9, 2021

Accounting

FASB considering enhanced income tax disclosures on global tax risks

July 7, 2021

A June 24 consultation on US Financial Accounting Standards Board (FASB) priorities shows the group is looking into enhanced income tax disclosures, including . . .

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

July 6, 2021

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Americas

US bill introduced in House to zero out base erosion and anti-abuse tax (BEAT) liability temporarily for 2020 as pandemic relief: Congressman Andy Kim (D-NJ)→

July 6, 2021

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.
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