The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Federal Reserve Board Chair Paul Volcker used to carry in his pocket a little slip of paper with hourly construction wages written on it.
By Lee A. Sheppard
Proposed regulations withdrawing the debt-equity documentation rules will help large corporations avoid spending $924 million in compliance costs over 10 years, but burdens continue with the remaining anti-inversion, anti-earnings-stripping rules.
By Emily L. Foster
By Molly Moses
Three years after the Organization for Economic Cooperation and Development came out with its base erosion and profit shifting plan, most tax incentives regimes for intellectual property development are now compliant, signifying that, as one OECD official said, “everybody is moving in the right direction.”
The IRS has proposed (REG-130244-17) removing final regulations (T.D. 9790) under section 385 that provide minimum documentation requirements for some related-party interests in a corporation to be treated as indebtedness for federal tax purposes and has proposed conforming changes to other final regs to reflect the proposed removal of the documentation rules.
By Tax Analysts
Although proposed regs fail to completely resolve ambiguity surrounding whether business interest limitations apply for purposes of calculating global intangible low-taxed income, until stated otherwise, they are arguably applicable.
By Andrew Velarde
By Molly Moses
A draft resolution recently released by European Union lawmakers contains an amendment that would let individual countries decide the percentage of a tax to be imposed on large digital companies.
By Michael Rapoport
Companies’ record stock repurchases this year are causing profits to appear stronger and fueling the stock market’s record run. A key driver in the surge of stock buybacks was last December’s tax overhaul, which lowered companies’ tax bills and freed up funds that many companies are using for share repurchases.
By Theo Francis
U.S. companies repatriated $169.5 billion in foreign profits in the second quarter—more than in most recent periods, but underscoring a cautious approach to shifting huge sums across borders. The figure marks a decline from a revised $294.9 billion in the first quarter, the three months immediately after Congress passed sweeping tax legislation.
Prime Minister Justin Trudeau’s government could make meaningful progress in addressing the nation’s competitiveness challenges even without taking the costly step of lowering the corporate tax rate, according to the head of the country’s biggest business lobby.
By Theophilos Argitis
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