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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
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.
To read more go here Subscription RequiredCurbing 'exorbitant tax privilege' is harder than it looks
By: John Thornhill
Pressure from voters has forced politicians to co-ordinate an international response
To read more go here Subscription RequiredTax Wars: How to End the Conflict over Taxing Global Digital Commerce
By: 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.
To read more go hereA Look Ahead: Prospects Unclear for U.S. Tax Treaties in 2020
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.
To read more go here Subscription RequiredA Look Ahead: On the Brink of a New Tax World Order, or Chaos?
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.
To read more go here Subscription RequiredBEPS Measures Have Ambiguous Economics Effects, IMF Paper Says
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.
To read more go here Subscription RequiredAustrian Coalition Deal Would Trim Corporate Tax Rate to 21 Percent
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.
To read more go here Subscription RequiredGoogle to end the use of 'double Irish' tax loophole
By: Richard Waters
Internet company to consolidate all of its intellectual property in the US
To read more go here Subscription RequiredFrance and US seek to resolve digital tax dispute
By: Victor Mallet and Kiran Stacey
Officials to hold talks to head off new round of US trade sanctions
To read more go here Subscription RequiredFundamentals of Tax Reform: BEAT, 2019 Final and Proposed Regulations
By: 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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