The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Archives: July 2018Subscribe
By Ryan Finley
In holding that Congress authorized “purely internal” approaches to allocating income among related parties, the Ninth Circuit’s reversal of Altera departs from prior decisions’ insistence that IRS authority is confined to the comparables-based
By Tax Analysts
An initial outline listing discussion points for House Republicans’ “tax reform 2.0” legislation offers a hodgepodge of recycled retirement proposals, promises to make temporary provisions permanent, and a plan to help start-up businesses.
By Manoj Viswanathan
Tax compliance in the United States has long relied on information from centralized intermediaries — the financial institutions, employers, and brokers that help ensure income is reported and taxes are paid. Yet while the IRS remains tied to these centralized entities, consumers and businesses are not. New technologies, such as the “sharing” economy (companies such as Airbnb, Uber, and Instacart) and the blockchain (the platform on which Bitcoin is based) are providing new, decentralized options for exchanging goods and services. Without legislative and agency intervention, these technologies pose a critical threat to the reporting system underlying domestic and international tax compliance.To read more go here
By Allison Christians, Wolfgang Schoen, Stephen E. Shay
In this foreword to International Tax Policy in a Disruptive Environment: A Special Issue, the authors provide an overview of the two-day interdisciplinary conference that took place in Munich on 14-15 December
2017,and offer a synopsis of the articles in this special edition of the Bulletin for International Taxation. The authors offer preliminary observations based on the conference and papers, including that despite its successes the BEPS Project has left unfinished business. In the face of reduced residence-based taxation of direct investment and tax competition for mobile activity and real investment, countries have yet to reach consensus on a residence-source or destination-based division of taxation rights. The international tax regime remains at a way station in coping with the disruptive forces of change.To read more go here
By William Hoke
As China remains locked in a tariff battle with the United States, China's executive branch on July 23 announced tax incentives and a bond program intended to boost domestic demand and support the economy.
By William Hoke
The German government's plan to make online platforms such as Amazon and eBay liable for VAT that is not paid by merchants selling on their websites may be unworkable, according to one observer.
By: John Butcher (Bloomberg BNA)
China on July 20 released a tax reform plan aimed at creating a more unified taxation system across the country. Reforms include integrating “national and local taxation offices at and below the provincial level to enable the taxation system to better play its supportive role in state governance,” and easing “collection procedures for taxes and fees, lower collection costs and improve the business environment.”
By: Lynnley Browning (Bloomberg BNA)
A new international tax that was supposed to deter U.S. technology and pharmaceutical companies from shifting their profits offshore could instead catch Wall Street banks in its crosshairs. The levy on international profits -- called Gilti -- is only supposed to kick in if a company is paying an especially low tax rate in foreign countries. But quirks in the way the tax is calculated mean it will likely hit big banks with offshore operations, even when they already pay effective foreign tax rates above the threshold.
By: Ali Qassim (Bloomberg BNA)
A U.K. proposal requiring the platform economy to pay employment tax for their workers would likely raise costs and workloads for the companies, which include Uber Technologies Inc., practitioners warn.
By: Matthew Kalman (Bloomberg BNA)
The introduction of value-added tax in the United Arab Emirates on Jan. 1 forced many companies to overhaul their invoicing and accounting systems and re-appraise their business operations. For the first time, businesses must check their supply-chain documentation for procurement and sales. They must also assess their supply chains for tax efficiency. Those tasks are complicated by the country's 23 “designated zones,” which are subject to special VAT rules. According to a practitioner, “a lot of people are confused about their supply chains running through free zones and designated zones. . . .”
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