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International Tax News Blog

  • IRS Changes Allocation Rules for Partners' Foreign Taxes

    by Laura Davison (Bloomberg)

    The special rule for preferential allocations of creditable foreign tax expenditures in a partnership applies only to allocations to a partner that are deductible under foreign law, and not to other items that give rise to deductions under foreign law, the IRS said in temporary and proposed rules.
    For the DTR story, go here. (subscription required)

    By Davison, Laura , posted on Thursday February 4, 2016
  • EC releases anti-tax avoidance directive

    by Joe Stanley-Smith (ITR)

    The European Commission (EC) has released a package of measures including a much-anticipated proposal for an anti-tax avoidance directive.
    For the ITR story, go here.

    By Stanley-Smith, Joe , posted on Tuesday February 2, 2016
  • Dutch Finance Secretary Explains EU State Aid Ruling

    by Alexandee Lewis (Tax Analysts)

    The Dutch Ministry of Finance on February 2 published a letter from State Secretary of Finance Eric Wiebes to the parliament in response to questions about the European Commission's ruling that the Netherlands' approval of Starbucks's transfer pricing arrangements constituted illegal state aid.
    For the WWTD story, go here. (subscription required)

    By Lewis, Alexander , posted on Thursday February 4, 2016
  • Temp Regs Crack Down on Partnership FTC Planning

    by Amy S. Elliott (Tax Notes)

    Treasury issued a set of temporary and final regulations February 3 that appear to target partnerships that separated creditable foreign tax expenditures (CFTEs) -- in particular, CFTEs related to withholding taxes -- from the related foreign income.
    For the TNT story, go here. (subscription required)

    By Elliott, Amy S. , posted on Thursday February 4, 2016
  • International Tax News - Edition 36 - February 2016

    by PwC

    International Tax News is designed to help multinational organisations keep up with the constant flow of international tax developments worldwide. Among the topics featured in this month's edition are:  

    • New rules and BEPS-inspired measures in France
    • Korean tax law changes for 2016
    • US tax extender and government funding legislation
    • IP Box alignment with BEPS Action 5 in Cyprus
    For the current edition, go here.
    By PwC, posted on Thursday February 4, 2016
  • First comprehensive analysis of Universal Credit's effects since cuts in July Budget

    by Institute for Fiscal Studies

    To combat tax avoidance, governments can either improve current tax rules through multilateral initiatives such as the OECD's base erosion and profit-shifting project or work on creating an entirely new corporate tax system, the Institute for Fiscal Studies said in a January 29 release.
    For the release, go here.

    By Institute for Fiscal Studies, posted on Monday February 1, 2016
  • ABA Meeting: Tax Bar Struggles With Proposed Change to Foreign Goodwill Rules

    by Amy S. Elliott (Tax Notes)

    The favorable tax treatment of outbound transfers of foreign goodwill and going concern value is set to change as soon as Treasury finalizes regs proposed in September 2015, and practitioners are already sweating over the choice they'll have to make: elect into recognition of a continuous stream of income associated with foreign goodwill and going concern value or roll the audit lottery dice.
    For the TNT story, go here. (subscription required)

    By Elliott, Amy S. , posted on Wednesday February 3, 2016
  • Brady Calls for Fresh Thinking on Tax Reform

    by Kaustuv Basu (Tax Analysts)

    House Ways and Means Chair Kevin Brady, R-Texas, said after a committee hearing February 2 that fresh thinking is needed on how the United States taxes business income and on how to get to a business tax rate that is 15 or 20 percent.
    For the TNT story, go here. (subscription required)

    By Basu, Kaustuv , posted on Wednesday February 3, 2016
  • Corporate tax reform should encourage investment, not profit-taking

    by Robert Atkinson (The Hill)

    The United States needs faster growth to create the good jobs and higher living standards that Americans expect. The best way to produce higher growth is to speed up the rate of investment in new capital equipment (which includes machines, equipment, software and the like), thereby boosting workers' productivity, which has lagged significantly since the end of the Great Recession. Unfortunately, current U.S. tax policies tend to do a poor job of rewarding capital investment. In fact, rather than encouraging new investments, tax policies encourage companies to distribute profits made from things they have done in the past. It is a recipe for resting on your laurels, not reaching for the future.
    For The Hill article, go here.

    By Atkinson, Robert , posted on Wednesday February 3, 2016
  • EU Anti-Tax Avoidance Package Presented to Parliament

    by Michael Scaturro (Bloomberg)

    The European Commission's top tax official briefed members of the EU Parliament on the commission's proposals to curb corporate tax avoidance ahead of a meeting with EU finance ministers.
    “The package we presented agrees to a great extent with what you have set out in your reports,” EU Commissioner for Economic and Financial Affairs, Taxation and Customs Pierre Moscovici told members of the European Parliament (MEPs) on Feb. 2 in Strasbourg.

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

    By Scaturro, Michael , posted on Thursday February 4, 2016