International Tax News Blog

Archives: February 2019

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  • CFC Partners Must Adjust E&P for Section 951 (a) Inclusions

    Irish power management multinational Eaton Corporation PLC, which is facing tax-related litigation on multiple fronts in the United States, was dealt a blow by the U.S. Tax Court concerning the consequences of partnership section 951(a) inclusions.

    Tax Analysts By Amanda Athanasiou

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    By Athanasiou, Amanda, posted on Tuesday February 26, 2019
  • U.S. Chamber Comments on Proposed Hybrid Regs

    The U.S. Chamber of Commerce has sent the IRS a chart identifying issues arising under proposed regulations (REG-104352-18) on section 951 and section 951A hybrid arrangements, providing suggested solutions and explanations the group believes will be helpful in addressing those issues.

    Tax Analysts By Tax Analysts

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    By Tax Analysts, posted on Friday February 22, 2019
  • OECD and U.N. Eye Next Steps for Tax Inspectors Without Borders

    The OECD-U.N. Tax Inspectors Without Borders (TIWB) initiative may expand its scope to include other tax issues beyond tax audits, with pilot programs starting soon.

    Tax Analysts By Stephanie Soong Johnston

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    By Soong Johnston, Stephanie, posted on Tuesday February 26, 2019
  • OECD Faces Tough Test With Global Minimum Tax

    Structuring a uniform and comprehensive global minimum tax regime could be a technically difficult process at the OECD level.

    Tax Analysts By Jennifer McLoughlin

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    By McLoughlin, Jennifer, posted on Tuesday February 26, 2019
  • EU Parliament Report Criticizes Proposed Digital Services Tax

    Although the OECD's failure to address the tax challenges posed by digitalization leaves a void, a report found the proposed digital services tax would apply too broadly and may cause economic distortions and international retaliation.

    Tax Analysts By Ryan Finley

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    By Finley, Ryan, posted on Tuesday February 26, 2019
  • German Coalition Nearing Agreement on R&D Tax Incentive Proposal

    Germany’s Ministry of Finance said government ministers are discussing proposals for research and development tax incentives but would not confirm reports that the benefit would cost the government at least €1.5 billion a year.

    Tax Analysts By William Hoke

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    By Hoke, William, posted on Tuesday February 26, 2019
  • EU Law Sufficient to Deny Tax Break in Cases of Abuse, CJEU Says

    Member states should deny tax relief provided in directives that companies exploit to advance abusive or fraudulent agendas, even in the absence of domestic law combating such abuse, according to the EU’s highest court.

    Tax Analysts By Jennifer McLoughlin

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    By McLoughlin, Jennifer, posted on Wednesday February 27, 2019
  • Groups Urge IRS to Exclude CFCs From Interest Limitation Rules

    Treasury’s proposed regulations that apply business interest expense limitations under the Tax Cuts and Jobs Act to controlled foreign corporations are inconsistent with congressional intent and would create complex, burdensome rules, industry groups say.

    Tax Analysts By Emily L. Foster

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    By Foster, Emily L., posted on Wednesday February 27, 2019
  • Tech Group Suggests Changes for Business Interest Regs

    The Information Technology Industry Council has requested changes to proposed section 163(j) regulations (REG-106089-18) regarding the definition of interest and exclusions from the definition, the application of the interest limitation to controlled foreign corporations, the group CFC election, and the depreciation phaseout.

    Tax Analysts By Tax Analysts

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    By Tax Analysts, posted on Monday February 25, 2019
  • Irish Drug Maker Pursues Judicial Review of 1.6 Billion Tax Bill

    Irish pharmaceutical giant Perrigo Co. PLC has mounted an aggressive response to what is widely considered one of the largest corporate tax assessments in Irish history, and is seeking assistance from the Irish High Court.

    Tax Analysts By Amanda Athanasiou

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    By Athanasiou, Amanda, posted on Wednesday March 27, 2019


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