Canadian Digital Tax May Cost U.S. Firms $2 Billion Annually
Canada’s digital services tax might cause U.S. companies to lose up to $2.3 billion annually, and if the United States doesn’t push back, the “global contagion” of DSTs will spread, a tech industry group said.
Let’s Play Fair: Reconsidering the U.S. Corporate Tax System
Roy Clemons argues that the United States should replace its quasi-territorial tax system and proposes a framework that taxes domestic and multinational corporations at the same statutory tax rate on a country-by-country basis.
Startling Results From Recent Country-by-Country Reports
Martin A. Sullivan examines newly released IRS data that reveal surprising shifts in where U.S. multinationals book profits and losses, with some of the usual suspects absent and Gibraltar topping the tax haven list.
Honda Eyes New Canadian Tax Credits for C $15 Billion Investment
Honda is the latest automaker to announce a multibillion-dollar investment in Canada, bolstered by new investment tax credits introduced by the federal government to support the green transition.
The New U.N. Framework Convention: Plurilateralism Could Be a Key to Success
Peter Hongler and Simon Habich explain that upcoming U.N. negotiations should look to establish the institutional groundwork for a more credible evolution of the international tax system, recognizing that a global consensus may not be imperative across all tax-related domains, and instead should strive for global inclusivity.
Pace on U.N. Convention Is Rushing Consensus, EU Official Warns
Building consensus takes time, so the quick pace of the U.N.’s work on the terms of reference for a new framework convention on international tax cooperation is worrisome, a top EU tax official said.
EU Report Calls for Circumvention of Unanimity Rule for Taxation
A report commissioned by EU leaders on the future of the single market calls for a harmonized tax framework and says allowing exceptions to the unanimity rule could take a bite out of tax avoidance.
EU Leaders Brace for Tough Talks on Competitiveness, Tax Law
EU heads of state are scheduled to discuss how to strengthen the bloc’s single market and competitiveness, and some member states are determined to debate even the most politically sensitive proposals, with potential tax implications.
Australia’s Green Tax Credit Plan Aims to Compete With U.S. IRA
The “Future Made in Australia” plan, which will form part of Australia's upcoming budget and address the green energy transition, will contain strict tests for receiving tax credits and subsidies.
Companies Reconsider Research Spending With Tax Deal Held Up in Senate
Large U.S. companies are pressing lawmakers to revive expired tax breaks for research and development spending, as a political stalemate keeps some finance executives wrestling with those investments.
G-24 Looks Beyond OECD Tax Reforms and Toward the U.N.
The two-pillar OECD tax reform plan doesn’t go far enough to help developing countries, so the G-24 is hopeful for more progress under a U.N. framework convention for international tax cooperation, the group’s director said.
Stakeholders Say Australian Public CbC Reporting Requires Conformity
Nana Ama Sarfo reviews some responses to Australia's most recent public country-by-country reporting consultation and notes how the measure raises larger questions about international standardization.
European Commission Gets Mixed Messages Regarding Tax Wish List
EU leaders plan to adopt a draft statement calling for the harmonization of corporate tax law to advance the Capital Markets Union, but the European Commission’s meetings with tax officials tell a different story.
Moves to Adopt Pillar 2 Will Help U.S. in OECD Guidance Talks
U.S. progress on implementing OECD global minimum tax rules would put American negotiators in a better position to ask for U.S.-friendly pillar 2 administrative guidance, according to a top Treasury official.
EU Talks on Remote Workers Show Progress Is Possible on PEs
An EU task force looking at taxing rights over remote teleworkers appears to be leaning toward bilateral arrangements, and the possibility of triggering permanent establishments is a recurring theme in the talks.
JCT Mulling Ways to Refine U.S. Pillar 2 Revenue Estimates
The Joint Committee on Taxation is monitoring the implementation of global minimum tax rules around the world as it considers how to update its analysis of pillar 2’s potential U.S. revenue effects.
Canada Studies IP Box Initiative
Nathan Boidman, Marc André Gaudreau Duval, and Michael N. Kandev give an overview of IP box regimes, discuss whether it would be advantageous for Canada to adopt one, and examine the Canadian government’s perspective on the issue.
Senate Wins Fight With House Over OECD Budget
House appropriators tried to punish the OECD for its tax policies by eliminating its federal funding for fiscal 2024, but the organization instead got a 4 percent budget boost, according to a State Department document.
Liechtenstein Approves Ordinance Clarifying Pillar 2 Legislation
The Liechtenstein government has approved an ordinance that clarifies the interpretation and implementation of the country’s new law implementing a global minimum tax on large corporate groups.
The Implementation of Global Minimum Tax in ASEAN Countries
Melani Dewi Astuti provides a status check on Southeast Asian countries’ adoption of the global anti-base-erosion rules and examines the challenges these countries face in the wake of pillar 2, including limitations on offering tax incentives.
OECD to Soon Release Updated Pillar 2 Commentary, Official Says
The OECD expects to publish in the coming weeks updated commentary for the pillar 2 global anti-base-erosion rules that will incorporate previous rounds of administrative guidance, an OECD official said.
EU Council Presidency Closing In on FASTER Directive
The list of outstanding issues in the European Commission's Faster and Safer Relief of Excess Withholding Taxes proposal is narrowing, but EU member states are still divided over which transactions to exclude from the text.
EU Likely Won’t Ratify U.N. Tax Convention if It Undoes OECD Work
The EU will engage with the U.N. tax cooperation process to reach a broad consensus, an EU tax official said, stressing that the process should not undo important work on the OECD two-pillar plan.
European Commission Proposes Path to End Unanimity in Tax Votes
The European Commission has raised the possibility of moving the EU Council from unanimity to qualified majority voting on tax and other matters as part of a strategy for integrating new member states.
Saint-Amans Suggests External Tax Borders to Fund EU Budget
Pillar 2 of the OECD’s global tax reform plan could have presented an opportunity to merge resources for the EU budget — for example, through the undertaxed profits rule — according to an international tax expert.
Offering Refundable Tax Credits Is Not ‘Gaming’ the GLOBE Rules
Jefferson VanderWolk takes exception to criticism of the use of refundable tax credits, explaining that in fact refundable tax credits are a legitimate policy response to the current GLOBE rules.
EU Prepares for Future Talks With U.K. on Harmful Tax Practices
The EU will soon put in motion a 2020 commitment to hold annual talks with the United Kingdom regarding measures to counter harmful tax practices, according to a draft European Commission/EU Council statement.
Funding Needed to Make U.N. Tax Talks Inclusive, Colombia Says
The terms of reference for a proposed U.N. convention on international tax cooperation should provide for funding to ensure that the least developed countries can attend upcoming negotiations in New York, a Colombian official said.
Hot Assets, Source, and Hypothetical Sales: How the Rawat Court Made Hash Out of Simple Rules
Kimberly S. Blanchard examines the U.S. tax treatment of a sale of a partnership interest by a foreign person and explains why the Tax Court’s decision in Rawat was incorrect.