United States–MNE Tax

Americas

US–Swiss competent authority arrangement implementing tax dispute arbitration published: Internal Revenue Service→

August 11, 2020

Americas

Indonesia adds Facebook, TicTok, Amazon, Apple subsidiaries to list of foreign digital companies required to collect 10 percent VAT from customers beginning September: Eisya A. Eloksari / The Jakarta Post→

August 7, 2020

Americas

UN committee proposes new model treaty provision altering taxation of automated digital services

August 6, 2020

The UN Committee of Experts on International Cooperation in Tax Matters today released a proposed optional UN model tax treaty article that would grant additional taxing rights to countries where an automated digital services provider’s customers . . .

First Look: US IRS issues final and proposed regulations on interest deduction limits

July 31, 2020

The US IRS on July 28 released final and proposed regulations that implement limits to the tax deduction for interest expense enacted . . .

Americas

North Carolina announces voluntary transfer pricing resolution initiative: North Carolina Department of Revenue→

July 31, 2020

Americas

District of Columbia to vote on bill expanding sales taxes to sales of advertising services, scope of tax unclear: LexisNexis→

July 22, 2020

Americas

DC Council rejects proposed advertising and personal information sales tax: LexisNexis→

July 24, 2020

Americas

US issues final and proposed regulations on income subject to a high rate of foreign tax

July 21, 2020

The US IRS on July 20 issued a final regulations addressing the treatment of income earned by certain foreign corporations . . .

Africa

G20 finance ministers again pledge to agree on new multinational group tax rules by year-end

July 20, 2020

In a communique released after their July 18 virtual meeting, G20 finance ministers and central bank governors said that despite the disruptions created by the COVID-19 pandemic, they . . .

Americas

Study finds US tax reform did not affect US taxation of foreign earnings, both domestic and international firms benefited from reduced taxation of domestic earnings: Scott Dyreng, Fabio B. Gaertner, Jeffrey L. Hoopes, Mary Vernon / SSRN→

July 16, 2020

Europe

EU court reaches surprising conclusions in Apple state aid case

July 15, 2020

Aisling Donohue, a Partner, Andersen, Dublin, discusses today’s ruling by the General Court of the European Union quashing a decision by the European Commission that Ireland had granted Apple an illegal State aid, focusing on the likely next steps in this litigation . . .

Americas

US releases redesigned draft partnership tax form to clarify international tax reporting: Internal Revenue Service→

July 15, 2020

Americas

US Republican and Democrat Senate leaders reiterate support for retaliatory tariffs on France if DST not repealed: The United States Senate Committee on Finance→

July 14, 2020

Americas

US imposes 25 percent tariff on USD 1.3b French luxury goods in retaliation for French DST but suspends tax for up to six months: Doug Palmer / Politico→

July 11, 2020

Americas

First Look: IRS finalizes guidance on deduction for foreign-derived intangible income and global intangible low-taxed income

July 9, 2020

The US IRS today issued final regulations that provide guidance for corporations on the deduction . . .

Americas

EU General Court should conclude that Apple branch’s stateless income should not be taxed in Ireland because assets, functions, risks not located there, Irish economist says: Seamus Coffey→

July 9, 2020

Africa

OECD publishes model rules for tax reporting by gig economy platform operators

July 8, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the OECD’s July 3 release of model rules for tax reporting by platform operators. . .

Americas

US IRS issues guidance for consolidated groups regarding net operating losses: Internal Revenue Service→

July 7, 2020

Americas

US has not pulled out of digital tax talks, OECD’s Gurria says: Leigh Thomas / Reuters→

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

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

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 . . .

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

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

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

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 . . .

Americas

IRS corrects foreign tax credit regs: Internal Revenue Service→

May 21, 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

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