International Tax News Blog

Archives: November 2018

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  • Proposed FTC Regs Massively Complex, but Not Unexpected

    The proposed foreign tax credit regulations include extremely complex rules regarding allocation of expenses, among numerous issues, but largely follow the approaches practitioners thought Treasury would take.

    Tax Analysts By Alexander Lewis

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    By Lewis, Alexander, posted on Friday November 30, 2018
  • U.S. to Address Some Ordering Rules With PTI Guidance

    Treasury’s narrowed scope for forthcoming rules on previously taxed income (PTI) will include guidance on some of the ordering rules, but answers to other PTI questions will have to wait until the spring.

    Tax Analysts By Andrew Velarde

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    By Velarde, Andrew, posted on Friday November 30, 2018
  • APMA Sees No Fundamental Changes as a Result of BEPS Project

    Predictions that the IRS’s advance pricing and mutual agreement program would face a surge in disputes with foreign tax authorities emboldened by the base erosion and profit-shifting project have thus far failed to materialize.

    Tax Analysts By Ryan Finley

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    By Finley, Ryan, posted on Friday November 30, 2018
  • Chaos Concerns Propel Global Digital Tax Discussions

    Apprehension over a potential patchwork of digital taxation measures could compel countries to achieve consensus by 2020.

    Tax Analysts By Jennifer McLoughlin

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    By McLoughlin, Jennifer, posted on Friday November 30, 2018
  • Revised Voluntary Disclosure Rules Extend Penalty Framework

    New voluntary disclosure guidelines apply to both foreign and domestic disclosures and include a penalty framework and access to Appeals.

    Tax Analysts By Nathan J. Richman

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    By Richman, Nathan J., posted on Friday November 30, 2018
  • Individual Finds Disconnect in Term Used in Interest, GILTI Regs

    An individual has commented on a possible disconnect between the broad definition of interest in proposed section 163(j) regulations (REG-106089-18) and the narrower definition of interest expense in proposed regs (REG-104390-18) on global intangible low-taxed income regarding interest expense allocations.

    Tax Analysts By Tax Analysts

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    By Tax Analysts, posted on Thursday November 29, 2018
  • Mauritius remains a favourite among treaty shoppers

    International Tax ReviewBy Danish Mehboob

    Treaty shopping is still a common practice among taxpayers when investing in Africa, and Mauritius remains one of the best jurisdictions for minimising tax liabilities.

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    By Mehboob, Danish, posted on Friday November 30, 2018
  • Businesses call for wider Japan tax reform after consumption tax rise

    International Tax ReviewBy Alexander Hartley

    Japanese businesses are nervous that public pressure could again postpone an increase to the consumption tax rate, further delaying the overhaul of the tax system that they want.

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    By Hartley, Alexander, posted on Friday November 30, 2018
  • Tax Cut Working Better Than Advertised

    WSJ logoBy James Freeman

    Despite concerns over trade disputes and a slowing global economy, the corporate tax rate cut enacted in December of 2017 continues to encourage the business investment that leads to higher productivity and higher wages for American workers. Today the government reported that such investment was higher than it initially reported for the third quarter of the year.

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    By Freeman, James, posted on Friday November 30, 2018
  • Treasury Offers Halfway Solution to Companies Vexed by Foreign Tax Rules

    WSJ logoBy Richard Rubin

    The Treasury Department issued long-awaited corporate tax regulations on Wednesday, partly accommodating companies’ pleas for help with an unexpected consequence of last year’s tax law.

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    By Rubin, Richard, posted on Friday November 30, 2018


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