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The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
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Archives: August 2019
SubscribeThe Ninth Circuit’s Amazon Decision: A Meaningless Outcome?
By Ryan FinleyThe Ninth Circuit’s rejection of the IRS’s valuation method in Amazon under old law may not affect new cost-sharing disputes, but its observation on later revisions raises other questions regarding the transfer pricing regulations.
To read more go Subscription RequiredU.S. and France Strike Compromise Over Digital Services Tax
By Stephanie Soong JohnstonFrance intends to reimburse companies paying its digital services tax once a globally agreed approach on taxing the digital economy exists, a move that raises the stakes for ongoing negotiations, according to the OECD’s tax chief.
To read more go Subscription RequiredMexican Lawmaker Wants Foreign Digital Companies Subject to Tax
By William HokeA leading congressman in Mexico’s governing party recently introduced legislation to amend VAT and income tax laws so that foreign companies providing digital services are considered to have a tax domicile in Mexico.
To read more go Subscription RequiredFrench-U.S. Digital Tax Accord Fraught with Pitfalls, Firms Warn
By Stephanie Soong JohnstonAs France cheered an agreement with the United States to resolve tensions over its controversial digital services tax, trade groups warned it could lead to more pain than gain for companies and tax authorities alike.
To read more go Subscription RequiredDigital Services Taxes and Internation Equity: A Tribute to Peggy Musgrave
By Allison ChristiansAllison Christians considers the late economist Peggy Musgrave and her work’s lasting influence on modern-day tax and public finance policy, especially regarding efforts to tax the digital economy.
To read more go Subscription RequiredDebate Over Carbon Tax Heats Up as Canadian Elections Approach
By Tax AnalystWith Canada’s federal election scheduled to take place on or before October 21, Conservative Party members are warning that carbon taxes will go up if the Liberal government is reelected — a claim the Liberals refute.
To read more go Subscription RequiredMacron Embraces Leadership Role in Digital Taxation
By Teri SpracklandAllowing tech giants to avoid taxation where they make money is a “crazy” system that provides for a “constant tax haven,” French President Emmanuel Macron said.
To read more go Subscription RequiredComparing CFC Rules Around the World
By Sebastian DueñasSebastian Dueñas examines controlled foreign corporation tax regimes in Japan, France, Germany, the United Kingdom, Colombia, the Netherlands, China, and Spain, regarding the possible expansion of existing anti-base-erosion CFC regimes or the potential adoption of a minimum tax.
To read more go Subscription RequiredToward a 21st-Century International Tax Regime
By Reuven S. Avi-Yonah and Kimberly A. ClausingIn this article, the authors argue that the United States should consider adopting sales-based formulary apportionment and applying it to all large enterprises because it is more likely to lead to a stable outcome than recent OECD proposals and has important advantages relative to other proposals such as residual profit allocation by income or the destination-based cash flow tax.
To read more go Subscription RequiredBrazil’s Road to OECD Accession: Tax Transparency and BEPS Standards
By Rogerio Abdala Bittencourt Jr. and Antonio José Ferreira LevenhagenIn this article, the authors discuss how Brazil can align its tax rules with international standards in the areas of fiscal and financial secrecy, tax evasion, avoidance, and aggressive tax planning in preparation for accession to the OECD.
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