The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
The European Commission failed to convince the EU General Court that Belgium’s tax rulings exempting companies from tax on “excess profits” attributable to their being part of an international group constituted an illegal state aid scheme.
By Teri Sprackland
Treasury appears to be hedging its bets on its June 22 goal for delivering several pieces of international guidance from the U.S. Tax Cuts and Jobs Act that would statutorily allow retroactivity for its rules.
By Andrew Velarde
U.S. officials believe the OECD’s work on the digital economy will lead to a modest reallocation of taxing rights, most likely based on the marketing intangibles approach set out in the OECD discussion draft.
By Ryan Finley
Political pressures motivating some global digital tax discussions appear to originate principally from concerns with the business-to-consumer market, according to a U.S. Treasury official.
By Jennifer McLoughlin
Jurisdictions under the OECD’s Inclusive Framework on Base Erosion and Profit Shifting are working diligently on their treaty relationships and continue to make progress on timely and accessible dispute resolution mechanisms.
By Amanda Athanasiou
Austrian Minister of Finance Hartwig Loeger recently issued an ordinance on the application of the controlled foreign corporation tax regime. The ordinance, published in the official gazette on January 25, took effect January 1.
By Slim Gargouri
Lee A. Sheppard looks at how the Tax Court’s decision in Grecian Magnesite remains relevant, even after the passage of the Tax Cuts and Jobs Act.
By Lee A. Sheppard
New proposed section 951A regulations provide guidance on how consolidated groups should compute their global intangible low-taxed income. While the crux of filing a consolidated return is treating the group as a single taxpayer for purposes of calculating and paying a single tax liability, the proposed regulations (REG 104390-18) combine single taxpayer treatment with single-entity calculations.
By Carrie Brandon Elliot
A new world order is emerging from the OECD base erosion and profit-shifting project and U.S. tax reform. Those efforts, combined with larger economic and political forces, have mostly laid waste to the previous international tax regime.
By Mindy Herzfeld
All of the OECD’s new proposals for taxing the digital economy — including the U.S.-favored marketing intangibles approach — would radically depart from the arm's-length principle, compounding growing international pressures on traditional transfer pricing principles.
By Ryan Finley
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