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International Tax News Blog

  • EU Refers Belgium to Court of Justice Over Taxation of Foreign Collective Investments

    by Bloomberg Daily Tax Report

    The European Commission has referred Belgium to the Court of Justice for imposing a higher tax rate on foreign collective investment undertakings (CIUs) from other European Union member states than on those established domestically.
    For the story, go here. (Subscription required)

    By Bloomberg Daily Tax Report, posted on Tuesday October 21, 2014
  • News Analysis: Will PayPal's Spinoff End in an Inversion -- or Two?

    by Ajay Gupta (Tax Analysts)

    PayPal's announced spinoff from parent company eBay could open the door to one or both resulting entities moving offshore with foreign merger partners. Each of these expatriations, however, would encounter statutory and regulatory hurdles -- including those presaged in Notice 2014-52, 2014-42 IRB 1.

    For the analysis, go here. (subscription required)

    By Gupta, Ajay, posted on Monday October 20, 2014
  • News Analysis: Defining Harmful Patent Boxes

    by Mindy Herzfeld (Tax Analysts)

    The OECD is trying to determine the appropriate return for intangible assets in various action items of its base erosion and profit-shifting project.
    Action item 8 on intangibles has proved so controversial that the OECD has had to postpone part of the project until later this year. In the report on harmful tax practices, the OECD has determined that a preferential intellectual property regime should not be considered harmful if its tax benefit depends on the performance of substantial activities in the relevant jurisdiction. However, the OECD members have not been able to agree on what substantial activities means.
    For the analysis, go here. (subscription required)

    By Herzfeld, Mindy, posted on Monday October 20, 2014
  • Wyden's Approach to Inversions to Depend on Pace of Deals

    by Lindsey McPherson (Tax Analysts)

    With some companies reconsidering whether to pursue inversions following Treasury's notice about forthcoming guidance to address the issue, Senate Finance Committee Chair Ron Wyden, D-Ore., is monitoring the pace of inversion transactions to determine whether stopgap legislation is still needed or whether it can wait for comprehensive tax reform.

    For the story, go here. (subscription required)

    By McPherson, Lindsey, posted on Monday October 20, 2014
  • Italy May Change Valuation of Trademarks, Patents to Stop Big Companies From Leaving

    by Eric J. Lyman (Bloomberg Daily Tax Report)

    Italy's Ministry of Economic Development and the Italian Treasury announced a plan to change the calculation method of the value of trademarks, patents and some types of intellectual property, in order to lower the tax bill on those assets.
    The plan is in response to the relocation of headquarters outside Italy by several large Italian companies, which left at least in part to save on their tax bills.
    For the story, go here. (subscription required)

    By Lyman, Eric L., posted on Tuesday October 21, 2014
  • Ireland, Still Addicted to Tax Breaks

    by The Editorial Board (The New York Times)

    The Irish government decided last week to get rid of a tax loophole that has helped big multinational companies like Apple and Google avoid paying billions in taxes to any government at all. But hold the champagne: Ireland could well replace one problematic tax policy with another, leaving aggressive tax avoidance pretty much intact.
    For the editorial, go here.

    By The Editorial Board , posted on Monday October 20, 2014
  • Corporate profits should be result of ingenuity, not inversions

    by Ted Kaufman (Delawareonline)

    A number of American corporations are making news, and not in a good way.
    They have announced mergers with foreign companies so they can avoid paying U.S. taxes. They are seeking what is called a "tax inversion" and it allows an American corporation to merge with a foreign corporation, move their headquarters overseas, and with some accounting manipulations avoid paying most of their U S taxes.
    For the article, go here.

    By Kaufman, Ted , posted on Monday October 20, 2014
  • EU Antitrust Chief Decries Political Pressure in Google Case

    by Tom Fairless (The Wall Street Journal)

    Europe's top antitrust official criticized what he called the "defensive" and "irrational" response by European politicians to his investigation of Google Inc., and said separately that his department may launch more probes into alleged sweetheart tax deals for multinational companies.
    Spanish-born Joaquin Almunia -- who is preparing to step down as the European Union's competition commissioner in a few weeks -- said the political pressure that preceded his decision to reopen the four-year-old Google case for a fourth time was unprecedented. The commission has rejected three settlement offers by the U.S.-based Internet giant.
    For the story, go here.

    By Fairless, Tom , posted on Friday October 17, 2014
  • Apple, Amazon in E.U. tax crosshairs

    by Politico

    Apple, Amazon and Starbucks are now on high alert: Europe, unlike more plodding U.S. tax authorities, is swiftly moving to blast heavyweight corporations for playing shell games to skirt taxes on billions in profits.

    In the past several weeks alone, the European Commission accused Apple of manipulating the company’s tax rate, and it called out Amazon for using royalty payments to avoid taxation in Luxembourg. The crackdown is putting pressure on low-tax European countries like Ireland — which has attracted big name companies with tax benefits — to tighten the rules.
     
    “The EU has sort of just woken up to the fact that within its midst are a bunch of countries whose existences depends on luring” companies away from each other with sweet tax deals, said David Rosenbloom, director of the international tax program at New York University.
     
    For the story, go here.

    By Politico , posted on Friday October 17, 2014
  • Jack Lew, Investment Killer

    by The Wall Street Journal

    The Obama Administration keeps wondering why businesses don't invest more and why it gets no credit for what it claims is its wonderful economic recovery. Look no further than its new and increasingly successful campaign to prevent money that corporations earn overseas from returning to the United States. That's the practical economic impact as so-called corporate-inversion deals die in the wake of Treasury's September tax raid on cross-border mergers.
    For the editorial, go here.

    By The Wall Street Journal , posted on Friday October 17, 2014