The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
In this article, the author discusses the major regulations to implement the base erosion and profit-shifting project in China and analyzes the impact on tax administration and tax compliance. She also provides an outlook on China’s tax administration in combating BEPS.
In economic analysis, Martin A. Sullivan examines the overall tax effect of a U.S. multinational shifting profit among its controlled foreign corporations and finds that, due to a quirk in the basic architecture of the Tax Cuts and Jobs Act rules, moving income from the high-tax jurisdiction to the low-tax jurisdiction is not always a tax minimizing strategy and may in fact backfire.
The Ninth Circuit affirmed the Tax Court’s 2017 decision in favor of Amazon, holding that the transfer pricing regulations’ definition of the term “intangible property” excludes goodwill, going concern value, and other residual business assets.
By Danish MehboobTax heads at Amazon and Facebook said France’s digital services tax (DST) adds uncertainty to an already ambiguous international tax environment because other countries can opt to undermine a multilateral solution too.
By Alex M. ParkerRepresentatives from Facebook, Amazon and Google said complying with a new French digital services tax will present significant challenges, including creating new measures to track individual user data, while testifying at a U.S. trade representative public hearing Monday.
By ReutersMajor tech firms and U.S. tech industry groups said on Monday that France's new digital services tax undermines the global tax regime and multilateral efforts to reform it. Alphabet Inc's Google, Facebook Inc and Amazon.com Inc and major trade associations testified Monday against the tax at a hearing before the U.S. Trade Representative's office and other government officials.
By Alex M. Parker
Sen. Elizabeth Warren, a Democratic presidential contender, wants to use U.S. trade agreements as leverage to ensure compliance with international standards on preventing tax avoidance — an approach that could make both trade and tax negotiations much more complicated.
By Jim Tankersley
Mr. Trump’s tax cuts unquestionably stimulated the American economy in 2018, helping to push economic growth to 2.5 percent for the year and fueling an increase in manufacturing jobs. But statistics from the government and other sources do not support Mr. Trump’s claim about his policies’ effectiveness in drawing investment and jobs from abroad.
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