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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.

    Tax Analysts By Andrew Velarde

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    By Velarde, Andrew, posted on Monday December 17, 2018
  • No 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.

    Tax Analysts By Ryan Finley and Jennifer McLoughlin

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    By Finley, Ryan and McLoughlin, Jennifer, posted on Monday December 17, 2018
  • U.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).

    Tax Analysts By Jennifer McLoughlin

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    By McLoughlin, Jennifer, posted on Monday December 17, 2018
  • Split 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.

    Tax Analysts By William Hoke

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    By Hoke, William, posted on Monday December 17, 2018
  • Australian 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.

    Tax Analysts By William Hoke

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    By Hoke, William, posted on Monday December 17, 2018
  • Transition 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.

    Tax Analysts By Andrew Velarde

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    By Velarde, Andrew, posted on Thursday December 13, 2018
  • E-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.

    Tax Analysts By William Hoke

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    By Hoke, William, posted on Thursday December 13, 2018
  • Interpreting 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.

    Tax Analysts By Alfred Chan

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    By Chan, Alfred, posted on Thursday December 13, 2018
  • Ireland, 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.

    Tax Analysts By Jennifer McLoughlin

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    By McLoughlin, Jennifer, posted on Wednesday December 12, 2018
  • Irish 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."

    Tax Analysts By Tax Analysts

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    By Tax Analysts, posted on Tuesday December 11, 2018


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