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The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.

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  • Arm's-Length Standard Is Flexible Enough for Digital Economy

    Tax Analysts

    by Ryan Finley

    The digitalization of the economy may create challenges in applying traditional transfer pricing methods, but the arm's-length standard is still a better approach than formulary apportionment, according to an IRS official.

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    By Finley, Ryan, posted on Thursday July 19, 2018
  • The OECD-Led International Compliance Assurance Programme: A Game Changer?

    Tax Analysts

    by Satoru Araki

    In this article, the author discusses the background, significance, and potential implications of the International Compliance Assurance Programme, a pilot initiative recently launched under the auspices of the OECD.

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    By Araki, Satoru, posted on Thursday July 19, 2018
  • Italyís New Capital Gains Tax Regime for Nonresident Companies

    Tax Analysts

    by Roberto Romito

    In this article, the author discusses measures in Italy’s 2018 Budget Law that could result in a higher capital gains tax burden on foreign companies disposing of shares in Italian entities and that may, in practice, conflict with EU law. He offers suggestions to companies affected by the change, noting issues they should take into consideration when planning for and calculating Italian taxes.

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    By Romito, Roberto, posted on Thursday July 19, 2018
  • Narrower OECD Profit-Split Guidance Is a Result of U.S. Efforts

    Tax Analysts

    by Ryan Finley

    Although some countries will inevitably apply the OECD's final profit-split method guidance more aggressively than intended, the actual language adopted by Working Party 6 reflects a successful U.S. effort to limit the method’s scope.

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    By Finley, Ryan, posted on Friday July 20, 2018
  • BEPS Has Not Caused Mutual Agreement Procedure Overload

    Tax Analysts

    by Alexander Lewis

    Despite practitioner warnings, the OECD’s base erosion and profit-shifting project has not spurred a flood of mutual agreement procedure cases, according to an IRS official.

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    By Lewis, Alexander, posted on Friday July 20, 2018
  • TCJA's Impact on Intangible Valuation Is Uncertain

    Tax Analysts

    by Ryan Finley

    Beyond the direct effects on intangible valuation mandated by the Tax Cuts and Jobs Act, the new law may affect how projected cash flows and discount rates should be determined when valuing intangible transfers.

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    By Finley, Ryan, posted on Friday July 20, 2018
  • U.S. Must Step Up Action on Beneficial Ownership, OECD Says

    Tax Analysts

    by Stephanie Soong Johnston

    The United States must do more to ensure that the availability of beneficial ownership information fully conforms to new international standards, the OECD’s transparency body said in a recent report.

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    By Soong Johnston, Stephanie , posted on Tuesday July 17, 2018
  • TCJA Will Deplete Multinational Tax Revenue Abroad, IMF Says

    Tax Analysts

    by Amanda Athanasiou

    The U.S. corporate tax cut will reduce tax revenue from multinationals by modest percentages under existing global policies, the IMF says, but if countries respond with policy changes, the loss could be much greater.

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    By Athanasiou, Amanda, posted on Tuesday July 17, 2018
  • Spanish Cabinet Approves MLI

    Tax Analysts

    by Sarah Carpenter

    Spain’s Council of Ministers on July 13 approved the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), according to information published by the Spanish government.

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    By Carpenter, Sarah, posted on Tuesday July 17, 2018
  • Parlez-Vous Wayfair? Foreign Lessons on Taxing Remote Sales

    Tax Analysts

    by Robert Goulder

    In this article the author analyses the Supreme Court’s landmark decision in Wayfair, and its implications for foreign businesses that sell goods to U.S. consumers.

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    By Goulder, Robert, posted on Tuesday July 17, 2018