United States–MNE Tax

Arturo Treviño Villarreal, a Tax Partner at Fratelli Consultores, Monterrey, Mexico, discusses new Mexican rules which entered effect on January 1 that address the income tax and VAT treatment of digital services and transactions performed on technological platforms . . .

Americas

Professor highlights importance of third-party asset valuation to protect US tax system from abuse: Leandra Lederman / SSRN→

February 3, 2021

Americas

US IRS large business and international unit adds compliance campaigns on Puerto Rico individual investors act, taxable asset transactions: Internal Revenue Service→

February 2, 2021

Americas

In a call with French finance minister Bruno Le Maire, US Secretary Janet Yellen committed “to re-engage actively in the ongoing OECD discussions on international taxation to forge a timely international accord”: US Department of the Treasury→

January 28, 2021

Americas

US Democrat senators introduce bill applying GILTI on a per-country basis, eliminating companies’ ability to deduct 10 percent of their tangible assets before GILTI applies: Sen. Amy Klobuchar→

January 28, 2021

Americas

US, Argentina agree to exchange country-by-country reports on large multinationals

January 28, 2021

The US and Argentina have signed a competent authority agreement to exchange . . .

Americas

In call to UK Chancellor of the Exchequer Sunak, US Treasury secretary Yellen discussed the need to find multilateral solutions to “efficiently and equitably” tax multinational firm income: US Department of Treasury→

January 27, 2021

Americas

In a call to German minister Scholz, new US Treasury secretary pledges active US participation in OECD international taxation effort “to forge a timely international accord”: US Department of Treasury→

January 27, 2021

Americas

US seeks feedback on burdens of reporting foreign currency transactions: IRS / Federal Register→

January 27, 2021

Americas

Janet Yellen sworn in as US Treasury secretary

January 26, 2021

Janet Yellen was sworn in Tuesday as the 78th Treasury secretary in US history . . .

Americas

Mark Mazur confirmed as US assistant secretary for tax policy

January 25, 2021

Mark Mazur, director of the Urban-Brookings Tax Policy Center and a former US Treasury Department assistant secretary for tax policy in the Obama administration, is the Biden administration’s new . . .

Americas

US IRS solicits comments on whether treaty-based return position disclosures are burdensome: Internal Revenue Service / Federal Register→

January 25, 2021

Americas

US Treasury nominee Yellen supports 28% corporate rate, 15% min tax on booked income, global min tax; pledges to work with OECD/G20 to resolve digital tax dispute: Reuters→

January 25, 2021

Americas

US Treasury nominee Yellen would delay corporate rate increase because COVID recovery takes priority, would work with OECD to stop tax “race to the bottom”: Thomas Franck / CNBC→

January 20, 2021

Americas

US IRS publishes final PFIC regs (TD 9936): US Treasury / Federal Register→

January 19, 2021

Americas

Day 1 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

January 19, 2021

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Americas

The origins of transfer pricing’s comparable profits method

January 6, 2021

Ednaldo Silva, Director, RoyaltyStat, Bethesda, Md., discusses the reasons why US IRS transfer pricing officials adopted the comparable profits method . . .

Americas

US IRS issues agent guide on qualified dividends and capital gains rate differential adjustments: Internal Revenue Service→

January 5, 2021

Americas

US, Turkey negotiating exchange of MNE country-by-country reports

January 4, 2021

The competent authorities of the US and Turkey have commenced negotiations for the exchange country-by-country reports . . .

Americas

Washington State legislators may soon debate digital advertising tax: Eversheds Sutherland SALT→

January 4, 2021

Americas

The end of the “double-Irish” tax structure means that a greater share of MNE profits are taxed in the US where the R&D generating the profits is undertaken: Seamus Coffey / Irish Examiner→

January 4, 2021

Digital Economy

Colorado revises regulation to clarify that sales of streaming digital goods are subject to tax: Charles Capouet & Todd Lard / SALT Shaker→

December 24, 2020

Americas

US Congress passes stimulus bill that extends PTC and ITC for land-based wind for one year at 60%, solar ITC for two years at 26%, gives offshore wind projects a 30% ITC, extends tax credit for carbon recapture by two years: Catherine Morehouse / Utility Dive→

December 23, 2020

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

Taxing multinational group excess profit in the US, UK, and Belgium

December 15, 2020

Dr. J. Harold McClure, New York, notes the EU Advocate General’s recent opinion concerning Belgium’s excess profits tax and discusses approaches to the taxation of these profits in the US, UK, and Belgium . . .

Americas

Canada’s bolder stance on unilateral digital taxes likely prompted by reduced fear of tariffs in Biden administration: Andy Blatchford / Politico→

December 15, 2020

Americas

US Senate follows House in passing law requiring existing and future US companies and LLCs to disclose information about beneficial owners: Jeanne Whalen / The Washington Post→

December 14, 2020

Americas

First Look: US releases final regs on source of income from sales of personal property

December 11, 2020

The US IRS on December 11 published final regulations (TD 9921) on the source of income from sales of inventory . . .

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