International

Tax Rate Modeling in the New World of US International Tax
Foreign branch versus CFC and the GILTI high-tax exclusion are two essential modeling imperatives

The world is getting smaller and more complex. National economies are more integrated globally, but national deficits and the need for tax revenues are driving unilateral measures. The original objective of the base erosion and profit shifting (BEPS) project has been described as ensuring that profits are taxed where economic… Read more »

Searching for Shangri-La: Reflections on the OECD’s Digital Tax Project
Analysis begins and ends with discussion of twin pillars

The goal of rewriting international tax rules to adapt more fully to the digitizing economy has eluded policymakers over the past decade. Efforts to find an acceptable solution at the global level so far have failed to muster consensus as different constituencies have raised perceived shortcomings that have halted progress,… Read more »

Global Mobility During a Pandemic
Workforce issues take center stage

The COVID-19 pandemic has disrupted how US businesses operate, causing significant challenges as many seek to adapt to a harsh economic reality that has continued into 2021. As businesses navigate the crisis, they have managed a seismic shift in how American and global workforces operate that has disrupted and redefined… Read more »

More Transparency in the EU: Questions & Answers on DAC 6
Are you up to date on cross-border arrangements?

The European Union (EU) passed a sixth version of its Directive on Administrative Cooperation in the Field of Taxation, known as DAC 6 (EU Council Directive 2018/822), on May 25, 2018. DAC 6 introduces reporting requirements for professional intermediaries (and, under certain circumstances, taxpayers) relating to their involvement in a… Read more »

OECD Races Toward Completing Final Report on Digital Economy
But two fundamental “pillars” present structural challenges

The Organisation for Economic Co-operation and Development (OECD) is racing toward meeting an ambitious target by the end of the year that could radically change the way all multinational enterprises (MNEs) are taxed. The target—a final report—was set forth in January 2019 under the cover of addressing the digital economy.1… Read more »

Unilateral Taxation of the Digital Economy
The fight is not over yet—it’s only beginning

Notwithstanding the recent efforts of the G20/OECD Inclusive Framework on BEPS (hereafter the IF) to develop a uniform, multilateral, and consensus-based solution for taxing the digital economy, legislatures and tax administrations around the world continue to propose and enact a host of largely uncoordinated digital services taxes (DSTs) and other… Read more »

Diving In: Platform Transactions and the OECD Digital Economy Effort
How the Model Rules address tax considerations related to the gig and sharing economy

Although much of the tax world has been focused on the Organisation for Economic Co-operation and Development’s two-pillar framework for addressing the tax challenges arising from the digitalization of the economy, a separate OECD effort with a potentially even broader reach is well underway. On February 19, 2020, the OECD… Read more »

Valuation Perspectives From Around the World
Increased analysis within financial reporting comes with increased levels of analysis required for tax reporting

The valuation of entities and assets is under greater scrutiny by tax authorities. Although valuation standards for tax purposes have generally lagged behind those for book purposes, new global standards require increased data, analysis, and support. This article will briefly review the developing and changing landscape and provide some practical… Read more »

Claiming a Foreign Tax Credit—How Exhausted Do You Really Have to Be?
Missteps by taxpayers in this area can be costly and result in avoidable double taxation

The Internal Revenue Service recognizes that “foreign government audits of U.S. taxpayers have become more frequent and, at times, more aggressive.”1 Consequently, the number of foreign tax contests and payments made by taxpayers to resolve those contests are on the rise. The IRS has signaled through its training materials and… Read more »

Deconstructing MAP and APA
Increased demand, new requirements to engage with IRS Examination, and efforts to come to terms with untested provisions of the TCJA have stretched APMA resources

In recent years, many taxpayers have effectively used mutual agreement procedure (MAP) cases and advance pricing agreements (APAs) to reduce or eliminate actual or potential double taxation due to inconsistent treatment of transactions with cross-border impact—most conspicuously for transfer pricing matters, but potentially for other issues as well. As the… Read more »

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