International Tax News Blog

Archives: September 2018

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  • News Analysis: Looming GILTI Battles

    The recently proposed regulations interpreting section 951A (REG-104390-18) were eagerly anticipated, yet mostly answered only the easiest questions about global intangible low-taxed income. Left for later are the more controversial topics that could require regulatory rewrites and whose resolution will likely affect companies’ projected 2018 effective tax rates, and thus, earnings. (Prior coverage: Tax Notes Int’l , Sep. 17, 2018, p. 1208.) Taxpayers disagree on many of the unresolved questions, so Treasury’s decisions could help some and hurt others.

    Tax Analysts By Mindy Herzfeld

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    By Herzfeld, Mindy, posted on Monday October 1, 2018
  • News Analysis: The TCJA: A Fourth-Quarter Playbook for Filers

    The Tax Cuts and Jobs Act continues to require tax groups to adjust and refine their book- and tax-reporting processes as they transition from 2017-tax-year rules to those that apply for 2018 and beyond.

    Tax Analysts By Carrie Brandon Elliot

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    By Brandon Elliot, Carrie, posted on Monday October 1, 2018
  • EU Competition Regulation Must Respond to Digitalization

    Competition regulation must keep up with the realities of digitalization and with new tools, expertise, and approaches, EU Competition Commissioner Margrethe Vestager said.

    Tax Analysts By Teri Sprackland

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    By Sprackland, Teri, posted on Monday October 1, 2018
  • Italian Budget Could Meet Resistance From European Commission

    After lengthy discussions that butted up against a deadline for announcing its budget targets, Italy’s ruling coalition said it will cut taxes and increase spending. Economists say the resulting deficit could violate EU target levels.

    Tax Analysts By William Hoke

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    By Hoke, William, posted on Monday October 1, 2018
  • Indian Supreme Court's About-Face Will Greatly Affect Exemptions

    The Supreme Court of India’s finding that ambiguously worded exemption clauses and notifications must be construed in the government’s favor has far-reaching implications because it overturns oft-cited precedent, according to practitioners.

    Tax Analysts By J.P. Finet

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    By Finet, J.P., posted on Monday October 1, 2018
  • Luxembourg Gave Double Nontaxation Deals to 70 Other Companies

    Luxembourg issued tax rulings allowing for double nontaxation to 70 companies besides McDonald’s, EU Competition Commissioner Margrethe Vestager said.

    Tax Analysts By Teri Sprackland

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    By Sprackland, Teri, posted on Friday September 28, 2018
  • IRS Still Considering TCJA's Effect on Transfer Pricing

    Key questions remain on how the Tax Cuts and Jobs Act’s international provisions will be coordinated with existing transfer pricing rules and advance pricing agreement practices as the IRS faces ongoing resource constraints.

    Tax Analysts By Ryan Finley

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    By Finley, Ryan, posted on Friday September 28, 2018
  • IRS Defends Authority for Antiabuse Rule on GILTI Basis Step-Up

    The IRS isn’t flinching in the face of criticism that it may have overstepped its authority to draft a basis step-up antiabuse rule under the proposed regs for the global intangible low-taxed income provision.

    Tax Analysts By Andrew Velarde

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    By Velarde, Andrew, posted on Friday September 28, 2018
  • Canadian Court Rejects Transfer Pricing Adjustments in Cameco

    A Canadian court reversed C $483 million (about $370.4 million) in adjustments to Cameco Corp.’s taxable income, holding that the company’s cross-border uranium sales were bona fide and properly priced using the comparable uncontrolled price method.

    Tax Analysts By Ryan Finley

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    By Finley, Ryan, posted on Friday September 28, 2018
  • Let Mauritian Financial Authorities Access Tax Data, FATF Says

    Mauritius should repeal statutory restrictions preventing its Financial Intelligence Unit from accessing tax data and start investigating tax evasion as a predicate offense of money laundering, a new Financial Action Task Force (FATF) report says.

    Tax Analysts By Stephanie Soong Johnston

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    By Soong Johnston, Stephanie, posted on Friday September 28, 2018


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