What We're Reading

EU CCCTB plan should include R&D tax incentive, paper concludes: Diego d’Andria, Dimitrios Pontikakis, Agnieszka Skonieczna / EU Commission→

August 15, 2017

Americas

US MNEs push for low rate for repatriated profits: Ginger Gibson / Reuters→

May 22, 2017

Americas

US should eliminate or revise regs under sections 987, 367, 482, 385, and 901(m), group says: United States Council for International Business→

May 13, 2017

Europe

German authorities receive leak revealing details of 70k Malta offshore firms, to pass data to other governments→

May 10, 2017

Americas

Caterpillar’s Illinois facilities raided in tax fraud investigation concerning Swiss operation profits: Swissinfo.ch→

March 7, 2017

See: Swissinfo.ch, More: Forbes, CNBC.

Americas

Apple, not US taxpayers, would pay bulk of $14.5 billion Irish tax bill if repatriation is via tax holiday: Jeffery M. Kadet / Forbes→

September 13, 2016

See: Forbes.

Americas

75 percent of US corp stock held by tax-exempt shareholders, including 26 percent owned by foreign shareholders→

May 17, 2016

See: Tax Policy Center.

Americas

US seeks greater transparency from foreign single-member LLCs in Delaware, Wyoming, and Nevada, Stack says: Anne Michel / Le Monde→

March 31, 2016

See: Le Monde (in French).

EU proposal will give states more power to set VAT rates: Francesco Guarascio / Reuters→

March 11, 2016

See: Reuters.

Americas

US studying retaliatory tax in response to EU state aid rulings: Richard Rubin / Wall Street Journal→

March 4, 2016

See: Wall Street Journal.

What We're Reading

India demands Vodafone pay 142 billion rupee (USD 2.1 billion) tax bill, threatens asset seizure: Siddharth Vikram Philip / Bloomberg Business→

February 17, 2016

See: Bloomberg Business. More: BBC News, The Times of India.

Americas

Barbados receives confirmation that OECD no longer views tax regime as harmful: tv6tnt.com→

January 30, 2019

Asia-Pacific

Australian transfer pricing guidance addresses inbound distributors in life science, information and communication technology, motor vehicle, other sectors: KPMG→

November 28, 2018

Americas

Judge won’t dismiss Medtronic shareholder suit over capital-gains triggered on move from US to Dublin: Joe Carlson / Star Tribune→

August 31, 2018

EU set to declare that French utility Engie’s Luxembourg subsidiary received State aid through private tax rulings: Foo Yun Chee / Reuters→

June 15, 2018

Americas

Bahamas House of Assembly passes country-by-country reporting law: Jones Bahamas / The Bahama Journal→

May 17, 2018

Asia-Pacific

Oman delays VAT: Reuters→

December 27, 2017

Europe

France: Finance Bill 2018 lowers corporate rate, abolishes profit distribution surtax and interest deduction antiabuse rule: Deloitte→

September 29, 2017

Americas

WTO backs Boeing in Washington State tax incentive dispute: CNBC→

September 5, 2017

Multinational

Professor identifies MLI implementation challenges: Johann Hattingh / SSRN→

August 15, 2017

Required 9 EU States to sign up for financial transaction tax, Austria’s Schelling says: Michael Shields / Reuters→

May 22, 2017

International Monetary Fund

Countries should extend thin cap rules to third-party borrowing, differentiate between sectors, IMF paper concludes: Ruud de Mooij & Shafik Hebous / IMF→

January 31, 2017

See: IMF.

Asia-Pacific

Indian circular clarifies coming GAAR: Central Board of Direct Taxes→

January 27, 2017

See: Central Board of Direct Taxes. *The circular will be analyzed in a forthcoming MNE Tax article.

Asia-Pacific

India rejects Singapore’s bid to delay revision of Singapore-India tax treaty: Business Standard→

October 10, 2016

See: Business Standard. Related: MNE Tax.

Americas

Apple EU State aid case reveals urgent need for US tax reform says US Treasury Secretary: Jacob J. Lew / The Wall Street Journal→

September 13, 2016

See: The Wall Street Journal (Subscription required).

Americas

Apple will not repatriate earnings unless US tax rate is cut, CEO says: Jena McGregor / The Washington Post→

August 16, 2016

See: The Washington Post. More: CNBC, The Street, Investopedia.

Americas

EU decision in Apple state aid case expected this fall: Natalia Drozdiak/Wall Street Journal→

July 18, 2016

See: Wall Street Journal.

Americas

US to require oil and gas companies to disclose payments to foreign governments beginning 2019: Eric Wolff / Politico→

July 8, 2016

See: Politico, More: OilPrice.com, Bloomberg BNA, Forbes.

Europe

Spanish tax authorities raid Google’s Madrid offices in VAT and income tax investigation: Matt Moffett and Sam Schechner / Wall Street Journal→

June 30, 2016

See: Wall Street Journal. More:The Guardian, Daily Mail, Reuters.

Europe

French authorities search McDonald’s in tax fraud investigation: Nick Kostov / New York Times→

May 27, 2016

See: New York Times.

Europe

Prosecutors seek probation, fines for Lux-leaks whistleblowers: Europe Online→

May 11, 2016

See: Europe Online.

Multinational

22 countries agree to obtain and share info on beneficial ownership of companies, trusts, foundations: Simon Bowers / The Guardian→

April 22, 2016

See: The Guardian. Source: HM Treasury.

FATCA/CRS

Lexisnexis® Guide to FATCA Compliance: Chapter 1 by William Byrnes, Robert J. Munro: SSRN→

March 10, 2016

See: SSRN.

Americas

US Tax Court denies Guidant Corp’s summary judgement motion, IRS can aggregate related transactions in transfer pricing adjustment→

March 4, 2016

See: Guidant Corp v. Commissioner, 146 T.C. No. 5. More: Nichols Patrick, CPE.

Europe

EU Commission staff analyzes financial transaction tax→

February 13, 2016

The paper, Financial Transaction Taxes in the European Union, was written by Thomas Hemmelgarn, Gaëtan Nicodème, Bogdan Tasnadi, and Pol Vermote. See: EU Commission.

Americas

MNEs with US activity vulnerable to US taxes on profits shifted to non-US group members using ECI theory, CPAs warn: Journal of Accountancy→

February 8, 2016

See: Profit Shifting: Effectively Connected Income and Financial Statement Risks, by Thomas J. Kelley, David L. Koontz, Jeffery M. Kadet. Available at: Journal of Accountancy.

Multinational

International Monetary Fund report gives advice to countries on crafting a general antiavoidance rule→

February 5, 2016

See: Introducing a General Anti-Avoidance Rule (GAAR) : Ensuring That a GAAR Achieves Its Purpose, by IMF legal department tax counsels, Christophe Waerzeggers and Cory Hillier.

EU Commission president open to public country-by-country reporting: James Crisp / EurActiv→

January 29, 2016

See: EurActiv.

Multinational

Profs argue that BEPS concerns better addressed if passive income taxed at source, active income taxed at residence, Reuven S. Avi-Yonah & Haiyan Xu / SSRN→

January 19, 2016

See: Why BEPS and MAATM are Inadequate Responses, and What Can Be Done About It, by Reuven S Avi-Yonah and Haiyan Xu. Available at: SSRN.

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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