Americas

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Thank you to our MNE Tax founder and community as we grow our platform

July 1, 2021

We are launching an exciting new chapter at MNE Tax, expanding our content and community of expert contributors in collaboration with our new parent CrossBorder Solutions. We would not have gotten to this point without . . .

Americas

US tells EU countries digital levy could jeopardize global tax talks

July 1, 2021

The Biden Administration has been reaching out to several European countries, according to June 30 reports, asking them to press the European Commission to put off a digital levy proposal that could. . .

Americas

US IRS ‘practice unit’ explains rules applicable to foreign tax redeterminations when a change in a taxpayer’s foreign tax liability affects previously claimed foreign tax credits: Internal Revenue Service→

June 30, 2021

Digital Economy

G7 global minimum tax deal leaves open questions

June 30, 2021

Vasiliki Koukoulioti, PhD researcher at Queen Mary University of London, discusses the questions that still surround the details of the global minimum tax agreement that G7 finance ministers reached on June 5 . . .

Americas

US Treasury Secretary stresses importance of India’s support for ‘robust global minimum tax’ in call with Indian Finance Minister: U.S. Treasury→

June 29, 2021

Americas

Argentina’s Economy Minister says 15% rate for global minimum corporate tax is too low, seeks rate of 21%–25%: Buenos Aires Times→

June 29, 2021

Accounting

FASB asks members to give feedback on group’s priorities, goals

June 29, 2021

The Financial Accounting Standards Board (FASB) on June 24 urged members to share their views on the group’s future agenda priorities and goals . . .

Americas

Japan–Uruguay tax treaty enters into force July 23

June 24, 2021

The tax treaty signed by the governments of Japan and Uruguay on September 13, 2019, will enter into force. . .

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

June 24, 2021

MNE Tax joins CrossBorder Solutions!

June 23, 2021

MNE Tax is excited to share that we have been acquired by CrossBorder Solutions, the global leader in technology-driven tax solutions . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

United States

US corporations pay lower effective tax rate than their foreign competitors and would likely continue to under proposed Biden corporate tax rate increase, according to Reuters analysis: Tom Bergin (Reuters) / Nasdaq→

June 23, 2021

Americas

New OECD toolkit guides Latin American and Caribbean tax authorities on applying value-added tax to e-commerce activities: OECD→

June 23, 2021

Canada

Canada updates guidance on competent authority procedures for taxpayers trying to resolve issues relating to double taxation or taxation not in accordance with an applicable tax treaty: Canada Revenue Agency→

June 23, 2021

Accounting

US IRS allows accounting method changes for depreciation of certain real property

June 23, 2021

On June 17, the US Internal Revenue Service provided guidance (Revenue Procedure 2021-28) explaining how a taxpayer changes its method of computing depreciation for residential rental property held by . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Americas

Argentina establishes simplified transfer pricing reporting regime

June 22, 2021

Hernán Ubertazzi, 3D Asesores, discusses the Argentine tax agency’s June 18 guidance simplifying the transfer pricing reporting regime to alleviate burdens on taxpayers that are considered . . .

United States

US IRS internal training document explains application of global intangible low-taxed income (GILTI) rules, including scope, computation, and allocation: Internal Revenue Service→

June 21, 2021

Mexico

Mexican Finance Secretary and US Treasury Secretary discuss importance of Mexico’s support within G20 for global minimum tax: U.S. Department of Treasury→

June 18, 2021

United States

US government bipartisan study on corporate tax reform finds that economic distortions caused by corporate taxes have declined over time and could be further reduced by additional changes: Congressional Research Service→

June 18, 2021

United States

US House passes bill to require public country-by-country reporting by SEC-registered multinational corporations: FACT Coalition→

June 18, 2021

Americas

US Senate approves bill with R&D funding for semiconductor industry

June 17, 2021

The US Senate passed with bipartisan support on June 8 a bill that would authorize new funding for research and development (R&D) to boost . . .

Americas

Biden will craft R&D tax incentives with congressional input

June 17, 2021

US Treasury Secretary Janet Yellen said during a June 16 Senate Finance hearing that strengthening tax incentives for research and development (R&D) . . .

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

June 16, 2021

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Accounting

FASB’s Investor Advisory Committee gives input on emerging issues, trends

June 16, 2021

The Financial Accounting Standards Board’s (FASB) Investor Advisory Committee met on May 25 to give its input on various FASB topics and trends . . .

Asia-Pacific

India has little to gain under G7 tax agreement

June 14, 2021

Suranjali Tandon, National Institute of Public Finance and Policy, discusses how, for developing countries like India, the agreement that the G7 finance ministers reached on June 5 may bring little new tax revenue while imposing . . .

Americas

Argentina introduces progressive corporate income tax

June 14, 2021

Rodrigo Marabi, LM Abogados, discusses the Argentine Congress’ approval on June 2 of a corporate income tax reform replacing the 30% fixed rate with a progressive tax rate . . .

Germany

Indonesian, Mexican, South African finance ministers join German, US counterparts in op-ed endorsing global minimum tax of at least 15%: Arturo Herrera Gutiérrez, Sri Mulyani Indrawati, Tito Mboweni, Olaf Scholz and Janet L. Yellen / Washington Post→

June 10, 2021

Americas

Biden tax plan sets aside money for R&D incentives, but details lacking

June 9, 2021

The Biden Administration proposes to enhance incentives for research and development (R&D) using revenue repurposed from the proposed repeal of the deduction for foreign-derived intangible income (FDII), according to . . .

Americas

Yellen says global minimum tax is necessary to preserve sovereignty

June 9, 2021

Harmful international tax competition, unchecked by any minimum tax, has eroded governments’ sovereignty to collect corporate taxes, stripping governments of funds necessary to address urgent fiscal priorities, according to a June 4 letter from US Treasury Secretary Yellen . . .

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

June 7, 2021

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

Americas

Coca-Cola says tax court erred in transfer pricing dispute, seeks reconsideration

June 7, 2021

The Coca-Cola Company on June 2 asked the US Tax Court to reconsider and set aside its November 2020 transfer pricing decision, in which it determined that Coca-Cola’s US income should be increased by . . .

Americas

Professor assesses Pillar One Amount A impact per country, industry: Lorraine Eden / SSRN→

June 7, 2021

Americas

Assessing business reaction to the TCJA and its guidance, GAO concludes that future international tax rulemaking should better assess paperwork burden and economic effects on business: General Accounting Office→

June 7, 2021

Austria

How will the European Commission define shell companies to stop tax avoidance?

June 7, 2021

New York City Economist Dr. J. Harold McClure discusses the European Commission’s launch on May 20 of an initiative to address the use of shell companies in international arrangements . . .

Americas

Perú tax authority considerations about the use of multi-year data in determining arm’s length transfer pricing

June 7, 2021

Zaida Limongi, TP Consulting Perú, discusses the Peruvian tax administration’s April 15 transfer pricing guidance . . .

Accounting

Canada consults on tax issues under new insurance accounting rules

June 4, 2021

Canada’s Department of Finance on May 28 launched a consultation on the tax implications of new international accounting rules for insurance contracts . . .

Americas

UK finance minister says US plan to break global tax deadlock could work: William Schomberg / Reuters→

June 4, 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.
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