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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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  • 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
  • Austrian Coalition Deal Would Trim Corporate Tax Rate to 21 Percent

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    By: AnnaGabriella Colon 

    Austria’s coalition government has announced a four-year program that calls for a corporate tax cut from 25 percent to 21 percent, as well as a revised goal of climate neutrality by 2040.

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    By Annagabriella Colon, posted on Friday January 3, 2020
  • Google to end the use of 'double Irish' tax loophole

    Financial Times

    By: Richard Waters 

    Internet company to consolidate all of its intellectual property in the US 

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    By Richard Waters, posted on Wednesday January 1, 2020
  • France and US seek to resolve digital tax dispute

    Financial Times

    By: Victor Mallet and Kiran Stacey 

    Officials to hold talks to head off new round of US trade sanctions

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    By Victor Mallet and Kiran Stacey, posted on Tuesday January 7, 2020
  • Fundamentals of Tax Reform: BEAT, 2019 Final and Proposed Regulations

    Bloomberg TaxBy: Kimberly Majure and John DerOhanesian

    On December 6, 2019, the IRS issued final BEAT regulations and the second set of proposed BEAT regulations. After a quick overview of the BEAT, the authors discuss the recently issued regulations, how the final regulations resolve questions raised by the 2018 proposed regulations, and the potential knock-on effects of the new regulations. 

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    By Kimberly Majure and John DerOhanesian, posted on Monday January 13, 2020


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