United States–MNE Tax

Americas

Nebraska introduces bill adding sales of digital advertising to sales tax base: Charles Capouet & Charlie Kearns / Eversheds Sutherland SALT Shaker→

January 27, 2020

Americas

US will retaliate if the EU adopts a carbon tax that is protectionist, commerce secretary warns: Gillian Tett, Chris Giles, & James Politi / Financial Times→

January 26, 2020

Americas

US’s Mnuchin says US could impose auto tariffs as retaliation against countries that impose digital taxes: Saleha Mohsin & Catherine Bosley / Bloomberg→

January 22, 2020

Americas

French minister announces US-France digital tax deal: through December France will impose but delay collection of DST, US will delay imposition of retaliatory tariffs: Pan Pylas & Jamey Keaton / AP→

January 22, 2020

Americas

Apple’s Tim Cook says international tax system needs revision: Padraic Halpin / Reuters→

January 21, 2020

Americas

France to delay DST, US to delay tariffs to allow more time for international tax deal, unnamed French officials say: James Politi, Mehreen Khan, Victor Mallet, & Martin Arnold / Financial Times→

January 21, 2020

Americas

IRS announces intent to grant some multinationals relief from double tax on deemed repatriation

January 20, 2020

The US IRS on January 17 announced that it will consider granting multinationals relief from double taxation resulting from . . .

Americas

US proposal for optional pillar one tax is a “non-starter” French minister says: Reuters→

January 17, 2020

Americas

Maryland lawmakers propose tax on digital advertising revenue

January 15, 2020

Maryland legislators on January 8 introduced a bill proposing a new tax on the revenue of large companies that advertise to individuals located in Maryland through a . . .

Americas

EU trade Commissioner Phil Hogan in US this week as digital tax dispute heats up: Doug Palmer / POLITICO→

January 13, 2020

US multinationals disagree on whether US should retaliate against France for DST: USCIB→

January 8, 2020

Americas

To avert trade war, US and France agree to seek digital tax compromise over the next 15 days: William Horobin & Laura Davison / Bloomberg→

January 7, 2020

Americas

US IRS updates guidance on obtaining private tax rulings

January 6, 2020

The US IRS on January 2 issued revenue rulings . . .

Americas

Any US trade action over French DST would lead to retaliation and WTO challenge, minister warns: Reuters→

January 6, 2020

Americas

Google to end use of ‘Double Irish, Dutch sandwich’ tax loophole: Edward Helmore / The Guardian→

January 4, 2020

Americas

Spain poised to enact digital services tax despite US threats of retaliation

January 2, 2020

Alma Delia Virto Aguilar, Ph.D., a visiting researcher at the University of Salamanca, discusses Spain’s plans to enact a digital services tax on the revenue of large multinationals . . .

Africa

Shell publishes country-by-country tax report

December 22, 2019

Oil giant Royal Dutch Shell on December 17 published its country-by-country report data for 2018 on the internet, providing . . .

Africa

US Treasury official defends “pillar one” safe harbor proposal for new global tax rules

December 20, 2019

A senior US Treasury official on December 19 said that the US is recommending that the OECD’s proposal for a “unified approach to pillar one” be rewritten as an optional safe harbor rule because even a watered-down version . . .

Americas

US IRS publishes proposed tax regs on allocation and apportionment of deductions and foreign taxes, financial services income, other topics

December 17, 2019

The US today published proposed tax regulations related to . . .

Americas

US IRS publishes final tax regulations on dividend equivalents

December 17, 2019

The US today published final tax regulations on dividend equivalents . . .

Americas

The final and proposed BEAT regulations: what changed, what’s new, and what’s next?

December 11, 2019

Amanda Varma, a partner with Steptoe & Johnson, Washington, DC, analyzes the final and proposed base erosion anti-abuse tax (BEAT) regulations, issued on December 2 . . .

Americas

France will challenge at WTO any US tariffs imposed in retaliation for DST, Finance Minister says: Geert De Clercq / Reuters→

December 11, 2019

Americas

US publishes US-France joint statement on implementation of spontaneous exchange of country-by-country reports on multinationals: US Treasury→

December 9, 2019

Americas

France rejects US plan to turn pillar one of tax rewrite into a “safe harbor,” says EU should negotiate digital tax if global agreement falls through: Tom Ozimek / Epoch Times→

December 9, 2019

Americas

US again delays effective dates of foreign currency tax regulation

December 9, 2019

The US IRS has announced that it will again delay by one year the effective date . . .

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 . . .

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

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

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 . . .

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 . . .

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