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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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  • Insight: The Classic Whip-Saw Effect of Customs and Transfer Pricing

    Bloomberg TaxBy: Damon V. Pike and Mark W. Schuette

    Tariffs and year-end transfer pricing adjustments present a unique conundrum in this era of trade wars. The authors analyze how tariffs can upset carefully planned transfer pricing arrangements and how to adjust those arrangements in response. 

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    By Damon V. Pike and Mark W. Schuette, posted on Monday January 13, 2020
  • Norway to Consider Digital Services Tax if OECD Talks Fail

    Bloomberg TaxBy: Hamza Ali

    Finance Minister Siv Jensen confirmed that the country would consider unilaterally implementing a digital services tax as soon as 2021 if international negotiations to rewrite tax rules for the digital economy fail to reach consensus.

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    By Hamza Ali, posted on Monday January 13, 2020
  • Treasury's Inconsistent BEAT Rationales

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    By: Mindy Herzfeld 

    Mindy Herzfeld discusses the recently released final section 59A regs, saying Treasury's explanations for granting some taxpayer requests and not others aren't logical.

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    By Mindy Herzfeld, posted on Monday January 6, 2020
  • France Vows Reprisals as US Hits Back at Digital Services Tax

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    By: Stephanie Soong Johnston 

    French Finance Minister Bruno Le Maire warned that his government would immediately go to the WTO to fight any sanctions imposed by the United States, which found that France’s digital services tax discriminates against U.S. companies.

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    By Stephanie Soong Johnston, posted on Tuesday January 7, 2020
  • U.S. Multinationals Support Tariff Response to French DST

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    By: AnnaGabriella Colon 

    The U.S. Trade Representative’s recommendation to impose tariffs on French imports in response to France’s digital services tax has received mostly positive reviews from U.S. companies, which want a multilateral solution to digital taxation.

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    By Annagabriella Colon, posted on Wednesday January 8, 2020
  • Curbing 'exorbitant tax privilege' is harder than it looks

    Financial Times

    By: John Thornhill 

    Pressure from voters has forced politicians to co-ordinate an international response

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    By John Thornhill , posted on Friday January 10, 2020
  • Tax Wars: How to End the Conflict over Taxing Global Digital Commerce

    Logo SSRNBy: Arthur J. Cockfield

    In the last two years, dozens of governments have proposed or introduced unilateral tax measures to tax foreign-based technology companies. The new tax innovations include special withholding taxes, diverted profit taxes, minimum taxes, and digital services taxes. The rise of these unilateral measures threatens an international tax ‘war’ among governments that could stifle new business models or even the spread of the global digital economy. This article reviews how international reform efforts have failed to constrain aggressive international tax planning and how the global digital tax conflict masks a growing dissatisfaction with how to tax value associated with global transactions. The author concludes that a coordinated solution that creates an economic presence test (a Quantitative Economic Presence Permanent Establishment) and modifies how tax revenues are divided between countries (e.g., the Residual Profit Split by Income proposal) is the best way to address these global developments.

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    By Arthur J. Cockfield, posted on Tuesday December 31, 2019
  • A Look Ahead: Prospects Unclear for U.S. Tax Treaties in 2020

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    By: AnnaGabriella Colon

    The outlook for U.S. tax treaties and the OECD multilateral instrument in 2020 seems uncertain, particularly in light of the stormy international trade climate among major trading nations, practitioners say.

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    By Annagabriella Colon, posted on Tuesday December 31, 2019
  • A Look Ahead: On the Brink of a New Tax World Order, or Chaos?

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    By: Stephanie Soong Johnston 

    The OECD is working at a breakneck pace to find a multilateral solution to update the international corporate tax rules for the digital age, and going into 2020, the stakes for that work have never been higher.

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    By Stephanie Soong Johnston, posted on Thursday January 2, 2020
  • BEPS Measures Have Ambiguous Economics Effects, IMF Paper Says

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    By: Ryan Finley 

    Although tax avoidance by multinationals has become an international political priority, it remains unclear whether anti-profit-shifting measures are economically beneficial for either high-tax or low-tax countries, according to an IMF working paper.

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    By Ryan Finley, posted on Thursday January 2, 2020


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