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International Tax News Blog

  • Etsy's B Corp Status Challenged by Tax Group Over Irish Haven

    by Alex Barinka and Jesse Drucker (Bloomberg)

    A tax policy advocacy group called for online retailer Etsy Inc. to be stripped of a certification awarded to companies that adhere to strict standards for transparency and social accountability unless it dismantles its offshore tax-cutting structure.
    For the Bloomberg story, go here.

    By Barinka, Alex and Jesse Drucker, posted on Tuesday September 1, 2015
  • International Tax News Edition 31 - September 2015

    by PwC

    nternational Tax News is designed to help multinational organisations keep up with the constant flow of international tax developments worldwide.
    For this month's issue, go here.

    By PwC, posted on Monday August 31, 2015
  • Regardless of IRS action, foreign implementation of country-by-country reporting means many US companies must file by end of 2017

    by PwC

    Action 13 of the OECD's Action Plan on Base Erosion and Profit Shifting (BEPS) strives to enhance transparency for tax administrations by providing them with adequate information to conduct transfer pricing risk assessments and examinations through increased transfer pricing documentation requirements, specifically including a new country-by-country report (CbC report) and a master file.  

    The OECD has recommended that the first CbC reports be required to be filed for multinational enterprises' (MNEs) fiscal years beginning on or after January 1, 2016.  The OECD also recommends that MNEs be allowed one year from the close of the fiscal year to which the CbC report relates to prepare and file it, meaning that the first reports would be filed by December 31, 2017, for companies with fiscal years starting January 1, 2016.

    Even if the United States does not implement CbC reporting, or delays implementation for one year, US-parented MNE groups will be required to file reports by the end of 2017 if the group includes entities with operations in a foreign country in which CbC reporting requirements have been implemented.  
    For the PwC Insight, go here.

    By PwC, posted on Tuesday September 1, 2015
  • OECD to Adopt Nexus Approach in BEPS Patent Box Guidance

    by Kevin A. Bell (Bloomberg)

    Early October guidance under Action 5 of the international project to combat base erosion and profit shifting will adopt a “nexus approach,” requiring intellectual property regimes to only grant preferential tax benefits in proportion to the taxpayer's research and development expenditures, an OECD official said.

    For the DTR story, go here. (subscription required)

    By Bell, Kevin A., posted on Wednesday September 2, 2015
  • Novartis Official: R&D Credit Should Cover Contract ResearchNovartis Official: R&D Credit Should Cover Contract Research

    by Kevin A. Bell (Bloomberg)

    The key issue for multinational pharmaceutical companies deciding where to locate a new research facility is whether the jurisdiction has a research and development credit that is available for contract as well as proprietary research, a Novartis AG official said.

    For the DTR story, go here. (subscription required)

    By Bell. Kevin A. , posted on Tuesday September 1, 2015
  • Trump Favors Profit Repatriation to Stem Corporate Inversions

    by William Hoffman (Tax Analysts)

    GOP presidential front-runner Donald Trump said he would favor repatriating trillions of dollars of corporate profits at a lower tax rate in order to create U.S. jobs and stem the tide of corporate inversions.
    For the TNT story, go here. (subscription required)

    By Hoffman, William, posted on Monday August 31, 2015
  • India Set to Resolve Disputes With 120 U.S. Companies

    by Madhur Singh (Bloomberg)

    India's Department of Revenue is close to resolving tax disputes with almost 120 U.S. companies in what analysts hope is an indication of the authorities' positive intentions and shift toward a more cooperative approach.
    Revenue Secretary Shaktikanta Das told a conference in New Delhi on Aug. 21 that the government is working to settle tax-related disputes with the U.S.-based companies, as well as those from Japan and elsewhere. Das stressed that the government doesn't intend to double-tax foreign entities in India.
    For the DTR story, go here. (subscription required)

    By Singh, Madhur, posted on Friday August 28, 2015
  • Industry Keeping Quiet on Boustany-Neal Innovation Box Draft

    by Aaron E. Lorenzo ( Bloomberg)

    Though details on a plan to lower tax rates on income from intellectual property emerged weeks ago, a fair bit of silence has followed.
    Mum has been the word for many would-be advocates and opponents alike.
    They seem to be holding back in anticipation of other proposals to change taxes on international profits in concert with the reduced rate for intellectual property, some observers said. Those added details are still to come, according to House Ways and Means Committee members and their staffers.
    For the DTR story, go here. (subscription required)

    By Lorenzo, Aaron E. , posted on Monday August 31, 2015
  • IRS Issues Agents Guidance on Foreign-to-Foreign Deals

    by Bloomberg

    When a transaction occurs that moves property from a controlled foreign corporation to a foreign corporation, IRS agents will be looking first at whether the controlled foreign corporation ceased to exist after the deal was done.
    In training materials provided to its examiners and released publicly Aug. 28, the Internal Revenue Service's Large and Mid-Size Business Division looks at the potential tax effects of certain foreign-to-foreign transactions on U.S. corporate shareholders who are making an exchange in the deal.
    For the DTR story, go here. (subscription required)

    By Bloomberg , posted on Monday August 31, 2015
  • Uproar in Brazil Over Proposal to Restore Financial Tax

    by Ed Taylor (Bloomberg)

    Brazilian government officials confirmed their intention to restore a controversial tax on financial transactions, provoking angry reactions from business leaders and economists.
    For the DTR story, go here. (subscription required)

    By Taylor, Ed , posted on Monday August 31, 2015