United States–MNE Tax

New York City economist Dr. Harold McClure discusses a difficult transfer pricing issue often faced by multinational apparel and shoe manufacturers, namely, how to treat locally incurred advertising expenses where the foreign parent formally owns the trademarks . . .

Americas

US IRS again defers start date of foreign currency tax regulations

September 17, 2020

The US IRS has again deferred the applicability date of foreign currency . . .

Americas

The protectionism of Biden’s cross-border tax plan

September 15, 2020

Daniel Bunn, Vice President of Global Projects at the Tax Foundation in Washington, analyzes US presidential candidate Joe Biden’s cross-border taxation proposals, made public last week, which aim to support his “Made in America” agenda . . .

Americas

Biden pledges to immediately reverse corporate tax cuts, raising rates to 28% from 21%: Joseph Zeballos-Roig / Business Insider→

September 11, 2020

Americas

Deriving receipts from New Jersey sources does not give foreign corporate limited partner nexus for corporate business tax purposes, court says: Eversheds Sutherland→

September 11, 2020

Americas

France says US blocking global digital tax talks: Reuters→

September 10, 2020

Africa

UN model treaty proposal would impose withholding tax on software payments

September 9, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .

Americas

US candidate Biden proposes 10% surtax on foreign affiliate sales to US customers, 10% tax credit for investment in US facilities or jobs, anti-inversion rules, doubling GILTI tax rate, country-by-country GILTI calculation: Daniel Bunn / Tax Foundation→

September 9, 2020

Americas

US priority tax guidance plan 3rd quarter update does not list any new international tax projects: US Department of the Treasury→

September 8, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Americas

Denmark reviewing Google’s tax payments: Reuters→

September 3, 2020

Americas

US IRS solicits public comment on whether the information production required to access competent authority assistance under tax treaties is overly burdensome: Internal Revenue Service / Federal Register→

September 2, 2020

Americas

US IRS to issue S corporation regs reflecting international tax changes

September 2, 2020

The US IRS on Tuesday announced in Notice 2020-69 that it intends to issue tax regulations . . .

Americas

US congressional staff reviews worldwide digital services taxes and US Section 301 trade investigations: Congressional Research Service→

September 1, 2020

Americas

First look: US IRS issues final BEAT regulations

September 1, 2020

The US IRS today released final regulations on the base erosion and anti-abuse tax . . .

Americas

GAO concludes that US businesses use offshore micro-captive insurance companies to improperly claim tax deductions: US Government Accountability Office→

August 31, 2020

Americas

US IRS now accepting applicants for 2021 Compliance Assurance Process program, allowing large publicly traded corps real-time tax issue resolution: Internal Revenue Service→

August 27, 2020

Americas

Covid-19 has accelerated foreign governments’ need to collect tax revenue from digital giants and the risk of US-led trade war: Vijay Govindarajan, Anup Srivastava , Hussein Warsame, & Luminita Enache / Harvard Business Review→

August 25, 2020

Americas

India’s Google tax contributes 1% of direct tax in IT hubs of Bengaluru and Hyderabad despite expansion to online e-commerce: Shrimi Choudhary / Business Standard News→

August 25, 2020

Americas

US publishes final regs on dividends received deduction limits, proposes regs on extraordinary distributions and GILTI

August 24, 2020

The US IRS and Treasury on August 21 published final regulations (T.D. 9909) on limitations . . .

Americas

US notifies Hong Kong of intent to terminate agreement allowing international shippers to avoid double tax: US Department of State→

August 21, 2020

Americas

US IRS makes correcting amendments to final regs on outbound property transfers and stock distributions by domestic corporations: Federal Register→

August 21, 2020

Americas

California holds hearing on bill requiring large corporations to publically disclose tax liability, tax credits claimed: Eversheds Sutherland SALT Shaker→

August 19, 2020

Americas

US makes minor corrections to final BEAT regs: Federal Register→

August 14, 2020

Americas

US IRS corrects final regs on hybrid dividends and arrangements: Federal Register→

August 12, 2020

Americas

US IRS corrects proposed regs that adjust hybrid deduction accounts to reflect E&P of CFCs included in income by US shareholders: Internal Revenue Service→

August 11, 2020

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