In an August 26 letter, Congressman John Larson (D-Conn.) urged House Ways and Means Chairman Richard Neal (D-Mass.) to include in the “chairman’s mark” of the budget reconciliation bill a four-year delay in the upcoming requirement for companies to amortize research and development (R&D) expenditures . . .
The West African nation of Togo became the 140th country to join the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) and the 134th Inclusive Framework member to endorse the two-pillar international tax reform statement released earlier this summer, according to an August 31 . . .
New York City Economist Dr. J. Harold McClure analyzes the situation surrounding the IRS’s large transfer pricing adjustments for 2010–2015 involving the intercompany pricing between Amgen’s US parent and its Puerto Rican manufacturing affiliate, with issues seeming to mirror those in Medtronic’s . . .
Senate Finance Committee Chairman Ron Wyden (D-Ore.) on August 25 released draft legislation for international tax reform that would retain but modify key provisions of the Republicans’ 2017 tax law, including the global intangible low-taxed income (GILTI) provision, foreign-derived intangible income (FDII), and . . .
Noopur Trivedi and Jitesh Golani, international tax researchers, analyze a hypothetical case study evaluating the effect that the intricate rules under the global anti-base erosion (GloBE) proposal in the July 1 OECD/G20 Inclusive Framework statement can have when implemented in a typical multinational . . .
Yuri Nikolaychuk, Rödl & Partner, discusses the Ukraine state tax service’s July 26 ruling concerning the tax implications of transactions between a Ukrainian taxpayer and a US limited liability company based in Texas, confirming that such transactions can be subject both to the transfer pricing rules . . .
Bijal Ajinkya and Raghav Kumar Bajaj, Khaitan & Co, discuss the Swiss tax authority’s August 13 confirmation that dividends received by an Indian resident from a Swiss company will be subject only to a 5% withholding tax rate in Switzerland, but if India does not reciprocate, the Swiss reserve the right to . . .
Thomas Schänzle, Christian Port, Florian Gimmler, Justus Eisenbeiß, Christian Witthus, Kevin Prashil Brusa and Rabea Lingier, Baker & McKenzie, analyze the far-reaching, practical implications of the amendments to the anti-treaty-shopping provision and transfer pricing rules in Germany’s Withholding Tax Relief Modernization Act (AbzStEntModG), which took effect June 9 . . .
Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .
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