The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Archives: April 2018Subscribe
By: Wendy Soong (Bloomberg BNA)
Standard & Poor's 500 banking industry first quarter earnings results concluded yesterday. All 18 banks in the industry group reported higher earnings compared to same quarter last year, in part due to the benefits from the tax plan implemented at the end of 2017. The aggregated effective tax rate of all 18 banks was reduced by 7 percentage points to an average of 19 percent compared to an average of 26 percent a year earlier.
By: Mark Vandevelde (Financial Times)
The White House will wait until after midterm elections in November before pushing forward with its plans to make last year’s tax cuts permanent, according to Steven Mnuchin, Treasury secretary.
By: Siri Bulusu (Bloomberg BNA)
India will continue to take its own steps to tax the digital economy, building on its equalization levy on digital advertising, unless international consensus is reached, an Indian tax official warned.
By: Mindy Herzfeld
The Tax Cuts and Jobs Act (P.L. 115-97) contains several provisions that question the premise of the regulatory authority granted by section 367(b) and how that authority has historically been interpreted by Treasury and the IRS. That’s because it’s no longer clear whether the reorganization provisions of the code still provide an effective tool for taxpayers to avoid U.S. income taxes in a cross-border setting. Whether any of the section 367(b) regulations make sense after enactment of the TCJA is an open question that has mostly escaped public notice.
By: Stephanie Soong Johnston
The European Commission is standing by its package of proposals to tax the digital economy despite concerns that they should be revised post-U.S. tax reform and also could slow down progress toward a long-term solution.
By: Zach Pouga and Vanessa Tollis
In this article, the authors examine the international provisions in the Tax Cuts and Jobs Act generally and then focus on how the changes will affect the tax efficiency of cross-border investment structures involving France and the United States. Many of the conclusions they reach can be extended to apply to investment structures involving the United States and other members of the European Union.
By: Tax Analysts
Illinois Tool Works Inc. has supplemented its prior request for guidance on the apportionment of some expenses to global intangible low-taxed income for purposes of the foreign tax credit limitation under section 904(a), providing further details on two issues that the company says are pertinent to the requested guidance.
By: Amanda Athanasiou
While global economic growth in the second half of 2017 was its strongest since 2010, the U.S. Tax Cuts and Jobs Act is expected to slow that roll starting in 2020, according to the IMF.
By: Stephanie Soong Johnston and Teri Sprackland
Germany will keep domestic business interests in mind while examining the European Commission’s plan to tax the digital economy, a Ministry of Finance spokesman told Tax Analysts. The country's business sector has urged caution regarding the commission's proposals, arguing they could harm domestic industry and escalate trade tensions with the United States.
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