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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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  • The NOL Carryback That Isnít, and the Worthless NOL That Is

    By: Eric M. Lopata

    In this article, Eric M. Lopata of Prudential Financial Inc. explains why a net operating loss carryback provision in the COVID-19 relief legislation will not have the intended stimulus effect unless Congress also addresses a problem caused by the application of the NOL computation rules to taxpayers with global intangible low-taxed income.

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    By Eric M. Lopata, posted on Thursday March 26, 2020
  • HMRC May Relax Anti-Hybrid Rules Amid Wider Antiavoidance Effort

    By: Ryan Finley

    As HM Revenue & Customs prepares to implement a series of new measures targeting tax avoidance schemes, the agency has signaled its openness to amending aspects of the hybrid mismatch rules criticized as disproportionate and overbroad.

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    By Ryan Finley, posted on Friday March 20, 2020
  • OECD Outlines COVID-19 Emergency Tax Measures for Governments

    By: Stephanie Soong Johnston

    The OECD has outlined several tax measures that countries can take to respond immediately to the economic fallout of the coronavirus pandemic with a clear message to governments: Do what you can to help taxpayers.

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    By Stephanie Soong Johnston, posted on Friday March 20, 2020
  • U.S. COVID-19 Bill Hits Company International Tax Fix Wish List

    By: Andrew Velarde

    Buried deep in the pages of a Senate bill to provide economic relief from the coronavirus pandemic are long-awaited Tax Cuts and Jobs Act technical corrections on transition tax overpayment and downward attribution.

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    By Andrew Velarde, posted on Monday March 23, 2020
  • Canada's High Court Dismisses Amazon Appeal

    By: Amanda Athanasiou

    The Supreme Court of Canada has dismissed an appeal by Amazon Inc., a major victory for customers who claim the company charged sales taxes that weren’t due.

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    By Amanda Athanasiou, posted on Monday March 23, 2020
  • Australian Research and Development Bill Faulted for Encouraging Foreign Competition

    By: William Hoke

    An Australian Senate committee is considering legislation to reform research and development tax initiatives that critics say is largely unchanged from a set of measures that failed to pass when first proposed in 2018.

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    By William Hoke, posted on Monday March 23, 2020
  • Big 4 Firms Throw Their Weight Behind Altera's Supreme Court Bid

    By: Ryan Finley

    Three of the Big Four accounting firms have added to calls for the Supreme Court to review Altera, arguing in an amici brief that the commensurate with income standard cannot justify the 2003 cost-sharing regulations.

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    By Ryan Finley, posted on Tuesday March 17, 2020
  • Trade Groups Seek Tariff Relief to Reduce Coronavirus Impact

    By: Annagabriella Colon

    Over 20 U.S. trade groups are calling on the Trump administration to eliminate section 301 tariffs, saying it is the only way to provide immediate relief from the financial burden of the coronavirus.

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    By Annagabriella Colon, posted on Tuesday March 17, 2020
  • EU to Ease State Aid Rules to Support Businesses

    By: Kiarra M. Strocko

    The European Commission has proposed that businesses affected by the coronavirus be allowed to receive direct grants and selective tax advantages of up to €500,000 to address urgent liquidity issues.

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    By Kiarra M. Strocko, posted on Wednesday March 18, 2020
  • OECD Global Tax Overhaul Work on Track Amid COVID-19 Crisis

    By: Stephanie Soong Johnston

    Despite the growing coronavirus pandemic, the OECD secretariat is still working “full steam” ahead on a solution to update the international tax rules for the 21st century — while using digital methods.

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    By Stephanie Soong Johnston, posted on Wednesday March 18, 2020


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