Int'l Tax News

Justin Trudeau spent awindfall on billions in tax breaks for Canadian businesses. Their response is that he still haswork to do.

Canada is offering tax incentives totaling C$14.0 billion ($10.6 billion) to offset the impact of President Donald Trump's tax reforms on the country's ability to compete for capital investment.

Companies that fallwithin a group structure are keen on Hungary's latest plan to help them reduce their collective tax by sharing corporate tax losses. The optionwould let affiliated companies set up a corporate tax group. Further, the planwould make it possible for these companies to eliminate the need to prepare domestic transfer pricing documentation.

Bankers are piling the pressure on the European Union to ensure all financial services receive a blanket exemption to the bloc's pending 3 percent digital services tax.

Companies in Europe are being advised towork now to complywith new rules requiring them to report certain aggressive cross-border tax planning arrangements to national tax authorities.

The European Union's digital tax geared at clawing back money from tech giantswould take effect in member states across the bloc by 2022 at the latest, according to a draft outlining a compromise legislative proposal by Austria,which holds the EU's rotating presidency.

Some of the biggest oil companies are looking for details on how to navigate the transition between the old U.S. international tax system and the new one. Representatives from the American Petroleum Institute and a number of major energy companies metwith officials from thewhite House's Office of Management and Budget on Nov. 19 to talk about soon-to-be-released proposed regulations and guidance on foreign tax credits and the base erosion and anti-abuse tax. The group is asking the OMB to include transitional details in those proposed regulations that clarify how the 2017 tax law treats net operating losses a company accrued before the law passed, and how companies can apply their old foreign tax credits under the law.

The nonpartisan Joint Committee on Taxation is set to release its explanation of the 2017 tax law soonÔøΩwhat's known as the "blue book." It may be the most anticipated edition yet of the publication.

Foot Locker Retail Inc., Gap Inc., and Deere & Co., commonly known as John Deere, all revised down their one-time 2017 tax overhaul payments in their most recent quarters.

U.S. insurance companies can be taxed twice on foreign earnings under one of the international provisions in the 2017 tax overhaul, even if those profits have been taxed highly elsewhere, insurers told the Treasury Department.

Australia is to require businesses seeking to tender for significant federal government procurement contracts to demonstrate their record of tax compliance. From July 1, 2019, tenderers for procurement contractsworth over AUD4m (USD2.9m) (inclusive of goods and services tax)will need to provide a statement from the Australian Taxation Office (ATO) to show that they have a satisfactory tax record.

Jurisdictions are beginning to create 'synthesised texts' to help taxpayers understand how the OECD's multilateral instrument (MLI) interactswith bilateral double tax treaties, but some believe they do not offer the legal clarity taxpayers seek and risk future disputes.

While some economies have continued to integrate new technology to improve their systems for the benefit of taxpayers aswell as tax authorities, other countries have trailed behind, introducing new taxeswithout technological advances, according to a report releasedwednesday by PwC and theworld Bank.

Canada onwednesday unveiled billions in economic measures aimed at jump-starting lackluster business spending and countering the risk of lost investment to the U.S. stemming from the Trump administration's tax reform.

White House Economic Adviser Larry Kudlow told reporters on Tuesday the next phase of U.S. tax reformwill not happen during the final months of 2018, the "lame duck" periodwhen Republicanswill still control Congress.

Tuesdaywas another down day in the markets amid concerns about global growth, U.S. interest rates and President Donald Trump's trade disputewith China. But investors suffering high market anxiety fortunately do not need towonderwhether tax competitivenesswill help the U.S. in the long run.

Internet-based companiesÔøΩranging from Amazon and Facebook, to Tinder and Alphabet Inc.'s GoogleÔøΩwill have to unravel the geographic origins of their revenue streams and customers to check if the U.K.'s digital taxwould apply to their businesses.

Robert Carroll and Brandon Pizzola of EY discuss the effect of 2017 tax law on the economies of the states. The authors find that there are variations across the states caused by the differences in the composition of state economies, the sunset of some tax-reducing provisions, and the delay of some tax-increasing provisions.

In this article, the author examines the opinion statement by CFE Tax Advisers Europe on the compatibility of limitation on benefit clauseswith EU fundamental freedoms and offers some insights.

Public records indicate that lobbying on the proposed base erosion and antiabuse tax continues evenwhile proposed regulations are being reviewed by the U.S. Office of Management and Budget.

Treasury and the Office of Management and Budget recently metwith several oil industry representatives as part of their regulatory review process in anticipation of the release of base erosion and antiabuse tax guidance.

Members of the European Parliament (MEPs) pushed for expanding the scope of the proposed EU digital services tax (DST) at a meeting of the Committee on Economic and Monetary Affairs (ECON).

The U.S. Chamber of Commerce has commented on proposed regulations (REG-104390-18) under section 951A on the inclusion of global intangible low-taxed income by U.S. shareholders, addressing the double taxation of high-taxed foreign income and seeking several changes to the regs, including clarification of an antiabuse rule andwithdrawal of a per se rule and the basis reduction rules.

The EU Code of Conduct Group has issued a report on the activities of the EU Council's Austrian presidency regarding business tax measures that the group assessed during the second half of 2018.

The United Kingdom may need at least two years to set up a functioning customs border and may temporarily forgo tariff collection in a no-deal Brexit scenario, a top HM Revenue & Customs official said.

In response to the U.S. Tax Cuts and Jobs Act, Canada has proposed three measures to boost its competitiveness,whichwould give it the lowest overall tax rate on new business investment among G-7 countries.

Congress makes tax laws, but accounting guidelines are mostly left for the Financial Accounting Standards Board, a private rulemaking body, to determine. As a result, the many international tax law amendments enacted by the Tax Cuts and Jobs Act (P.L. 115-97) don't necessarily result in any immediate changes to how companies should calculate their tax liabilities or determine their deferred tax assets or liabilities in their financial statements, nor how they should provide supplemental disclosures about their tax liabilities. The SEC's accounting guidelines for companies traded on the U.S. stock exchanges generally follow FASB's guidelines,which set rules for generally accepted accounting principles.

Canada's federal government is stepping in to help the struggling Canadian media industrywith new tax credits and incentives.

A proposed European Union digital tax should be set at 5 percent rather than 3 percent and should include revenue from sites such as Netflix Inc. and Amazon.com Inc., European Parliament lawmakers said Monday.

The Securities Industry and Financial Markets Association has commented on proposed regulations (REG-104390-18) under section 951A on the inclusion of global intangible low-taxed income by U.S. shareholders, focusing on a tailored basis adjustment rule and on the exception for qualified interest expense.

In this article, the authors discuss recent U.S. international tax developments, including guidance on basis adjustments, the Tax Court's decision in Smith, and treaty issues related to the Tax Cuts and Jobs Act.

Germany's economy needs a corporate tax cut to counteract the downturn in the third quarter, the country's economy minister said.

As the political climate over Brexit heats up, the European Commission faces the choice of quickly concluding its state-aid investigation into a controversial tax break for U.K.-based multinational companies.

A new "sunset" clause for the European Union's pending three percent digital services tax,whichwould see it being rolled out in 2021, got the cold shoulder from a host of countries in the bloc.

Rules requiring foreign companies to store certain types of data in India have opened a front in the country's quest forways to tax its booming digital economy. Tax professionals are exploringwhether data localization, as it is known, means digital companies are present in the country and therefore potentially subject to levies they hadn't previously had to pay.

Robertwillens discusses Ford Motor Co.'s attempt to gain interest netting for overpayments and underpayments made by it and itswholly owned foreign sales corporation. The companywas unsuccessful since it and the FSCwere not found to be "the same taxpayer."

Yes, the proposed GILTI regulations didn't answer some of the tough questions, particularly those surrounding the calculation of foreign tax credits. But the regulations do address other critical issues and suggests the general approach of Treasury and the IRS to drafting regulations under the 2017 tax actÔøΩwhich is to adopt regulations that Treasury and the IRS believe are consistentwith the overall statutory framework, and not regulations that unduly defer to specific statutory language that seems out of sync. This article summarizes certain key aspects of the proposed GILTI regulations relating to a controlled foreign corporation's qualified business asset investment.

The location of headquarters for the Fortune Global 500, the 500 largest corporations by revenue in theworld, has shifted significantly in recent years. Many factors can affect the choice of a company's headquarters location, such as regional economic growth and stability, local infrastructure, a country's regulatory environment, a country's tax policies, among others. Given the significant changes in countries' statutory corporate income tax rates during the 2000 to 2018 period, this article compares how headquarters locations and top statutory corporate income tax rates have shifted in recent years and discuses notable trends.

In the first of a four-part series on the fundamentals of international tax reform, Kimberly Majure and Barbara Rasch of KPMG LLP discuss the calculation of the deduction for foreign-derived intangible income (FDII). They explain the critical issues that require careful consideration and present planning opportunities, and they suggest best practiceswhile IRS guidance remains pending.

In the third of a four-part series on the fundamentals of tax reform, Barbara Rasch and Joshua Kaplan of KPMG LLP provide a general overview of the global intangible low-taxed income (GILTI) rules in new tax code Section 951A. They explain the issues involved in computing the GILTI inclusion, taking into account the guidance provided in the recently issued GILTI proposed regulations.

French President Emmanuel Macron's rapportwith German Chancellor Angela Merkel fails to hide frustrationwith slow progress on economic issues. The latest issue to expose deep divisions is an EU initiative, backed by France, to impose a revenue-based tax on big Internet companies.

A European Union court ruled on Thursday that a Spanish scheme to give a tax advantage to companies investing in foreign businesseswas illegal state aid that had to be repaid. Spain introduced a law in 2001 that allowed goodwill to be deducted from tax in the form of an amortisation for holdings in foreign companies of at least five percent if held for one year.

The Swiss Government has announced that, in preparation for a major overhaul of the tax system, existing practices on the taxation of principal companies and finance brancheswill not be applied to new companies as of 2019.

The OECD has provided a progress update on implementation of the BEPS multilateral instrument (BEPS MLI),whichwill become effective from January 1, 2019, and released advice for states on how to prepare guidance on the interpretation of changes to tax treaties.

Nigerian revenue authority leader Tunde Fowler has emphasized the importance of coming upwith a digital taxation solution thatworks for both developing and developed countries, aswell as the business community.

In a joint motion filed in a U.S. district court, Santander Holdings USA Inc. and the government asked to continue a status conference, stating that they have reached an agreement regarding foreign tax credits, deductions, penalties, and a refund related to Santander's participation in a structured trust advantaged repackaged securities transaction.

The General Court of the European Union in Deutsche Telekom AG v. European Commission, T-207/10 (GCEU 2018), upheld a European Commission decision (C(2009) 8107 final corr. of October 28, 2009) that Spanish tax provisions allowing for the amortization of financial goodwill of foreign acquisitions constituted illegal state aid, according to a GCEU release.

Developing countries should sign onto the OECD's multilateral instrument but adopt await-and-see approach to its more controversial provisions like mandatory binding arbitration, according to the Center for Global Development.

Effective January 1, Switzerland's Federal Tax Administrationwill no longer apply "federal practices" concerning principal companies and Swiss finance branches to new companies, the Federal Council said November 15.

The Austrian presidency of the EU Councilwill propose three different options for the rollout of the proposed digital services tax (DST).