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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 Isn’t, 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.
To read more go here Subscription RequiredHMRC 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.
To read more go here Subscription RequiredOECD 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.
To read more go here Subscription RequiredU.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.
To read more go here Subscription RequiredCanada'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.
To read more go here Subscription RequiredAustralian 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.
To read more go here Subscription RequiredBig 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.
To read more go here Subscription RequiredTrade 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.
To read more go here Subscription RequiredEU 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.
To read more go here Subscription RequiredOECD 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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