by Kristen A. Parillo and Andrew Velarde (Tax Analysts)
The Treasury Department on May 20 proposed sweeping changes to the model U.S. tax treaty, including limiting the availability of treaty benefits for taxpayers that benefit from special tax regimes and imposing full U.S. withholding tax rates on inverters.
by Laura Davison and Kevin A. Bell (BNA.com)
The Treasury Department's May 20 release, for public comment, of proposed changes to the U.S. Model Income Tax Convention are designed to have an impact on the work of the international project on base erosion and profit shifting, a Treasury official said.
by Rebecca Christie (BNA.com)
The European Commission will study possible compromises on an 11-nation financial transactions tax plan, spokeswoman Vanessa Mock said.
Finance ministers narrowed the range of proposals on the table last week in Brussels, without settling on a final plan.
by Amanda Athanasiou (Tax Analysts)The lack of consensus on controlled foreign corporation rules under the OECD's base erosion and profit-shifting project can be attributed in part to countries' self-interest and a misconception that transfer pricing rules can do the job, according to Robert Stack, Treasury deputy assistant secretary (international tax affairs).
by Stephanie Soong Johnson & David Stewart (Tax Analysts)
Data gathered through country-by-country reporting under action 13 of the OECD's base erosion and profit-shifting project may be better than existing data but won't be enough to give a full picture of the size and scope of BEPS, stakeholders said during a May 18 public consultation on action 11 of the project on improving BEPS analysis.
by Andrew Velarde (Tax Analysts)
Calling it "the hot idea" right now in Congress, Thomas Barthold, Joint Committee on Taxation chief of staff, on May 18 highlighted the challenges facing the construction of any patent or innovation box.
by Alison Bennett (BNA.com)
The Organization for Economic Cooperation and Development is considering establishing a compliance framework that countries could share as they work toward implementing the common reporting standard, an OECD adviser said.
by Rick Mitchell (BNA.com)
Policy makers should prepare for big shifts of companies' taxable profits and economic activity to source-taxation countries, spurred by possibly uncoordinated tax and transfer pricing rule changes growing out of the international action plan to combat base erosion and profit shifting (BEPS), a business practitioner said.
by David D. Stewart (Tax Analysts)
The OECD on May 15 revealed its preferred options on action 7 (preventing the artificial avoidance of permanent establishment status) in a revised discussion draft released as part of its base erosion and profit-shifting project.
by Laura Davison (BNA.com)
Calls from European Union officials that U.S. multinationals such as Google Inc. and Apple Inc. don't pay enough tax overseas are “hypocritical,” an analysis by the Progressive Policy Institute said European companies pay relatively less when they are in the U.S.