United States–MNE Tax

Americas

Switzerland rejects Biden’s tax haven claim: swissinfo.ch→

May 3, 2021

Americas

Bermuda leaders chafe at Biden’s tax haven label: Scott Neill / The Royal Gazette→

May 3, 2021

Accounting

FASB council considers cash flow statement, financial performance reporting changes

May 3, 2021

Members of the Financial Accounting Standards Advisory Council (FASAC) expressed support for certain improvements to cash flow statements in an April 8 meeting in which they discussed the importance for FASB to improve various financial reporting areas . . .

Americas

Biden plan would raise US MNE taxes by 81 percent, create incentives for profit shifting out of the US, think tank concludes: Cody Kallen / Tax Foundation→

April 29, 2021

Americas

Biden’s American Families Plan proposes additional IRS funds to scrutinize large corporation taxes: The White House→

April 28, 2021

Americas

GOP infrastructure counterproposal would seek to avoid corporate and international tax hikes through smaller plan and reallocated spending: Minority, US Senate Committee on Environment and Public Works→

April 28, 2021

Digital Economy

US state of Connecticut considers digital advertising tax with international implications similar to state of Maryland’s: Connecticut General Assembly →

April 28, 2021

Americas

Wyden touts plan to replace “hodgepodge” of oil and gas tax incentives with clean energy producer breaks: United States Senate Committee on Finance→

April 28, 2021

Americas

French and German finance ministers voice support for US proposal on global minimum tax: Reuters→

April 28, 2021

Americas

Google UK reports its 2020 financials: the transfer pricing implications

April 28, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Carbon Tax

Biden looking into carbon border adjustment tax like one under consideration in EU, John Kerry says: Yahoo Finance→

April 26, 2021

Americas

Global agreement on new nexus rules and minimum tax likely by October, Saint-Amans says

April 22, 2021

Momentum is quickly growing for agreement on the final policy approach for new international tax rules on country taxing rights under the OECD’s “Pillar One” . . .

Americas

US Treasury Secretary Yellen says tax moves needed to help tackle climate change

April 22, 2021

US Secretary of the Treasury Janet L. Yellen spoke on April 21 of the Biden administration’s “whole-of-government approach” to aggressively tackling climate change – including creating a targeted investment tax credit . . .

Americas

Google UK paid just £50 million (69.14 million USD) in corporate tax last year, despite posting £1.8 billion (2.49 billion USD) of revenues: Chris Newlands / inews→

April 22, 2021

Europe

Ireland positions itself as counterpoint to US in debate over global minimum tax

April 21, 2021

Irish Finance Minister Paschal Donohoe today confirmed that Ireland would resist the push for a global minimum tax to the extent that it would infringe on the country’s 12.5 percent corporate tax rate . . .

Accounting

FASB to host virtual credit loss panel

April 21, 2021

The Financial Accounting Standards Board (FASB) announced on April 20 that it will host a virtual roundtable next month on implementing the current . . .

Accounting

FASB appoints three members to small business advisory committee

April 21, 2021

The Financial Accounting Standards Board (FASB) on April 20 announced the appointment of three new members . . .

Americas

UN Committee of Experts approves new digital tax article for model treaty

April 20, 2021

The UN Committee of Experts on International Cooperation in Tax Matters today agreed to the text of a new article and commentary for the UN model tax treaty that would grant . . .

More News

Democrat bill aimed at fossil fuel industry would eliminate tax credits and subsidies, restrict deductions: Senator Edward J. Markey→

April 19, 2021

Americas

IRS asks for public input on priorities for tax guidance

April 19, 2021

The IRS has released an advance version of Notice 2021-28 that invites recommendations for items to be included in the 2021-2022– Priority Guidance Plan. The 2021–2022 Priority Guidance Plan will identify tax guidance projects that the Treasury Department and the IRS intend to

Americas

JCT provides overview of US tax system: Joint Committee on Taxation →

April 16, 2021

Americas

US proposes rules for foreign persons investing in qualified opportunity funds

April 14, 2021

The IRS published proposed rules on April 14 setting forth requirements that certain foreign persons and foreign-owned partnerships would have to meet to elect the tax benefits related to investing in qualified opportunity funds. . .

Americas

IRS warns taxpayers on microcaptive insurance arrangements

April 14, 2021

Participants involved in abusive microcaptive insurance arrangements should exit the transactions now and not attempt to claim associated deductions on their 2020 tax returns, the IRS said in an April 9 statement. . .

Americas

US confident “vast majority” of developed nations will approve global minimum tax, US deputy treasury secretary says: Thomas Franck / CNBC→

April 14, 2021

Americas

Wyden says Treasury’s OECD proposal would address digital taxes that discriminate against US companies while supporting US tax reform goals: US Senate Committee on Finance→

April 14, 2021

Americas

Groups criticize UN model tax treaty software proposal but for different reasons

April 14, 2021

Trade and civil society groups are critical of a proposal to revise the UN model tax treaty to include software payments within the definition of royalties. . .

Americas

NGO proposal revises minimum tax to overcome OECD approach’s shortcomings

April 14, 2021

The proponents of a new minimum effective tax rate proposal for multinational corporations say their proposal would modify the OECD’s proposed global anti-base erosion tax (GloBE) . . .

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

Americas

Countries should suspend their DSTs now to show they are serious about reaching global agreement on international tax, ranking member says: US Senate Finance Committee→

April 13, 2021

Africa

Leaked copy of US proposal for Pillar One and Two multinational group tax reforms available

April 12, 2021

MNE Tax has obtained a copy of a slide presentation outlining the US’s latest “Pillar One” and “Pillar Two” proposals for the reform of the international system for multinational group taxation. . .

Americas

India unlikely to agree to global minimum tax: Arup Roychoudhury / Moneycontrol→

April 9, 2021

Americas

Cyprus divided on Yellen’s minimum corporate tax: Andrew Rosenbaum / CyprusMail→

April 9, 2021

Asia-Pacific

Global minimum tax’s effect on Hong Kong could be an issue for China, support could be tied to US trade tariff concessions: Frank Tang & Orange Wang / South China Morning Post→

April 9, 2021

Africa

US offers new “Pillar One” compromise plan for taxing large multinationals

April 8, 2021

The Biden administration has proposed a new “Pillar One” scheme for taxing multinational groups to a coalition of 139 countries . . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Americas

Biden fleshes out international tax plan, Senate Democrats offer their take

April 7, 2021

A US Treasury Department report released on April 7 expands on the corporate tax plan announced by the Biden Administration last week . . .

Americas

US Treasury Secretary Yellen calls for G20 agreement on global minimum tax

April 5, 2021

US Secretary of the Treasury Janet Yellen said on April 5 that she is working to get buy-in from G20 nations on a global minimum corporate tax . . .

Americas

MNEs shifted USD 1 trillion in profits offshore to tax havens, ICIJ study says: Scilla Alecci / International Consortium of Investigative Journalists→

April 5, 2021

Europe

IRS claims Bristol Myers Squibb owes 1.38 billion in unpaid tax for inappropriate deductions following of transfer of patent rights to Irish sub, New York Times report says: Arlene Weintraub / Fierce Pharma→

April 1, 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