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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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PTI Notice Acknowledges Need for Greater Simplicity
The first tranche of guidance on previously taxed income (PTI) since the enactment of the Tax Cuts and Jobs Act (P.L. 115-97) may need greater simplicity to prevent “hyper-complexity,” a senior Treasury official said.
By Andrew VelardeTo read more go here Subscription RequiredNo Regulatory Authority for Further BEAT Relief
Although the proposed base erosion and antiabuse tax regulations take a taxpayer-favorable approach to the services cost method (SCM) exception, officials concluded that the statute doesn't support netting or a cost of goods sold (COGS) exception.
By Ryan Finley and Jennifer McLoughlinTo read more go here Subscription RequiredU.S. Downward Attribution Changes Are a Conundrum for Treasury
U.S. Treasury officials continue to assess the scope of their authority to help alleviate headaches associated with the increase in controlled foreign corporations under the Tax Cuts and Jobs Act (P.L. 115-97).
By Jennifer McLoughlinTo read more go here Subscription RequiredSplit Decision for Brazil in WTO Appeal Brought by Japan and EU
A WTO appeals body has returned a split decision on rulings by a dispute resolution panel acting on complaints brought by the EU and Japan that some Brazilian tax programs were prohibited subsidies.
By William HokeTo read more go here Subscription RequiredAustralian Tax Gap for Large Corporate Groups Shrinks
The Australian Taxation Office (ATO) said large corporate groups underpaid their taxes by an estimated AUD 1.8 billion (approximately $1.3 billion) during fiscal 2015-2016, or 4.4 percent of the total amount owed.
By William HokeTo read more go here Subscription RequiredTransition Tax FAQs Clarify Status of 2018 Overpayments
The IRS has released a new set of frequently asked questions on the transition tax, which includes a clarification that some overpayments for the 2018 tax year can be refunded.
By Andrew VelardeTo read more go here Subscription RequiredE-Commerce, Digital Audits Net $723 Million for Australia
The compliance efforts of an Australian Taxation Office (ATO) task force targeting e-commerce and the digital economy have resulted in over AUD 1 billion (around $723 million) in additional cash collections through June 30, 2018.
By William HokeTo read more go here Subscription RequiredInterpreting the MLI: A Guide to Analyzing the Treaty and Its Capital Gains Article
In this article, the author examines the structure of the OECD’s multilateral instrument, including the compatibility clauses and the use of opt-in, opt-out, and alternative provisions, with a focus on the capital gains provisions in article 9.
By Alfred ChanTo read more go here Subscription RequiredIreland, U.S. Seeking Global Tax Fix for Digital Economy
Officials on both sides of the Atlantic agree that a global solution for taxation in the digital era is best achieved through the OECD.
By Jennifer McLoughlinTo read more go here Subscription RequiredIrish Finance Minister Paschal Donohoe Discusses Digital Tax Challenges
In an address, Irish Finance Minister Paschal Donohoe discussed the current international tax environment and Ireland's work with the OECD and U.S. government to attain a global solution for digital tax challenges, noting that "it is in everyone’s interest that the ongoing work results in an international tax framework that is sustainable into the long run."
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