International

Nuts, Bolts, and Nuances of the Competent Authority Process
Relief is provided in most cases, but pitfalls and new issues are multiplying

The competent authority procedure is a dispute resolution mechanism available to taxpayers facing cross-border disputes under an applicable tax treaty. The taxpayer may invoke this procedure to require the tax administration’s competent authority function to “endeavor” to resolve the dispute by “mutual agreement” with its counterpart in the treaty partner… Read more »

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Tax-Efficient Supply Chain in Shadow of Tax Reform
GILTI, FDII, and BEAT: they’re not just acronyms—they require reassessing tax consequences of existing supply chain structures

For the past quarter century the same legal framework and economic incentives have driven how multinational corporations structure their supply chains. Relatively high U.S. corporate rates incentivized companies to locate valuable assets and operations in lower-taxed jurisdictions; the United States’ worldwide tax regime incentivized retaining and reinvesting those earnings outside… Read more »

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Anatomy of a Multijurisdictional Dispute
Recent tax reform presents additional considerations

Demands on tax executives have never been higher. Whereas international tax rules have always been complex, the Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting (BEPS) Action Plan and now U.S. tax reform introduce new levels of complexity and uncertainty. At the same time, sensational media coverage… Read more »

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Practical Questions for Multinationals in an MLI World
MLI moves to implementation with open issues and challenges

Now that the multilateral instrument (MLI)1 coordinated by the Organisation for Economic Cooperation and Development (OECD) has been signed by over seventy jurisdictions,2 the new international tax agreement has moved to the implementation phase, with open issues and challenges ahead. The practical outgrowth of the OECD’s project to address base… Read more »

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Indirect Taxes, Canada: Impact of Delivery Terms
Effect is significant on application of GST/HST on imports, exports, and sales

Canada imposes a five percent federal value-added tax called the goods and services tax (GST), which applies to the supply of most goods and services in Canada and to imports of most goods into Canada. Five Canadian provinces (Ontario, Nova Scotia, New Brunswick, Prince Edward Island, and Newfoundland and Labrador)… Read more »

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Indirect Taxes: India
Goods and services consumption tax heralds new era

India is witnessing one of the most significant events in its fiscal history with the introduction of the goods and services tax (GST), a single comprehensive destination-based consumption tax. The country’s current indirect tax system consists of the following taxes levied by the federal and state governments: The GST framework… Read more »

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Indirect Taxes: United Kingdom
Brexit expected to affect tax policy for at least a generation

On June 23, 2016, the United Kingdom voted in a national referendum on whether the UK should remain a member of the European Union. It was a simple in-or-out question asked of the British people, of whom 51.9 percent voted to leave the EU and 48.1 percent voted to remain.… Read more »

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Indirect Taxes, Canada: Cross-Border Developments
Court decisions, interagency tensions, and ETA amendments could significantly affect taxpayers doing business in Canada or with Canadian companies

Three recent Canadian goods and services/harmonized sales tax (GST/HST) developments may have significant consequences for and warrant close attention from those engaged in businesses either in Canada or outside Canada with business or financial interests in Canada, as well as their tax advisors. One of these concerns is whether the… Read more »

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Imports and Exports, Canada: What You Really Need to Know About GST/HST
The ins and outs of a multistage value-added tax payable by the ultimate consumer

When doing business with another country, the sales tax implications are an important consideration. It is possible for nonresidents of Canada1 to acquire goods and services in Canada for export without having to pay the goods and services tax/harmonized sales tax (GST/HST). It is also possible for nonresidents to provide… Read more »

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VAT Extends Global Reach
Why Don’t We Have VAT in the U.S.?

Question: What do more than 160 countries have that the United States does not? Answer: A value-added tax (VAT) VAT is a broad-based consumption tax, chargeable at every stage of the supply chain, up to the retail stage, that generally allows the recovery of input tax for businesses and results… Read more »

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