The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
German Chancellor Angela Merkel said on Tuesday that if there was no international agreement on taxing digital companies by the second half of next year, Europe should go ahead anyway.
Similarities between regulatory language in the foreign-derived intangible income provision and section 199 guidance could mean that regs under the defunct statute will inform taxpayers on applying FDII’s foreign use rule for general property.
By Andrew Velarde
The potential impact of a global minimum tax proposal on countries’ taxing sovereignty was a commonly raised issue during the OECD’s public consultation.
By Jennifer McLoughlin
Despite international progress on profit shifting, there are still policy gaps concerning opaque offshore ownership structures and corporate tax avoidance that are costing developing countries needed tax revenue.
By Amanda Athanasiou
Final regulated investment company rules clarify the treatment of subpart F and passive foreign investment company income inclusions, reversing Treasury and the IRS’s 2016 proposed regulations.
By Emily L. Foster
In light of the profit-split method’s potentially expanded role under a new regime for taxing the digital economy, the EU Joint Transfer Pricing Forum (JTPF) will explore ways to improve the method’s clarity and simplicity.
By Ryan Finley
The European Commission has released a report by the Centre for European Economic Research analyzing the possible impacts of the draft common corporate tax base directive of October 2016 on the effective corporate tax burdens in EU member states.
By Tax Analysts
Stephanie Soong Johnston delves into the OECD's March public consultation at its headquarters in Paris, where some of the tax world's brightest minds gathered to discuss adapting the international tax rules for the digital age.
By Stephanie Soong Johnston
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