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US Archive

  • August 2019

    US digital giants worried about domino effect from French DST

    August 16, 2019

    Tax heads at Amazon and Facebook said France’s digital services tax (DST) adds uncertainty to an already ambiguous international tax environment because other countries can opt to undermine a multilateral solution too.

  • California’s VAT back tax ‘devastating’ for third-party sellers

    August 14, 2019

    California’s pursuit of back-taxes from third-party sellers on Amazon and other online marketplace sites risks bankrupting small businesses. Amazon is failing to accept responsibility, sellers claim, and it’s a worldwide problem.

  • US companies gain benefits under tailored carbon taxes

    August 09, 2019

    Multinational companies, including ExxonMobil and Microsoft, are supporting a corporate-friendly US carbon tax with trade-offs where they pay more tax in exchange for tax certainty, including protection from emission disputes.

  • What to expect at the IFA 2019 Congress

    August 09, 2019

    International Tax Review speaks to IFA President Murray Clayson about the prospects for “radical change” on digital tax and why the London Congress will focus on BEPS Action 4 and the challenges facing investment funds.

  • Disclosures show whistleblowing standards benefit tax departments

    August 07, 2019

    Data from internal corporate disclosures show that internal procedures and systems for whistleblowing are improving corporate governance and inter-departmental trust within companies, but tax heads are hesitant about the results that create a paper trail.

  • Blockchain could create tax certainty in transactional taxes

    August 05, 2019

    In-house blockchain experts and consultants say companies and tax authorities can use distributed ledger technology to report and administer transactional taxes as real-time reporting increases.

  • Euromoney Legal Media Group Americas Rising Star Awards: Shortlist announced

    August 05, 2019

    Euromoney Legal Media Group has announced the shortlist for its second annual Americas Rising Stars Awards.

  • Investors disappointed by former Yahoo! company’s tax strategy

    August 02, 2019

    Altaba, a former Yahoo! entity, will begin liquidating its assets in the coming months, but corporate investors say the liquidation is not the most tax efficient option, nor what they were expecting.

  • July 2019

    DSTs thrust into political limelight

    July 31, 2019

    As France’s digital services tax takes retroactive effect and the UK releases more details, tax heads spoke of a nightmarish cocktail of uncertainty and high politics.

  • Americas Tax Awards 2019: Nominees announced

    July 25, 2019

    The nominees for the 14th annual Americas Tax Awards have been announced.

  • Tax heads: Here’s how to influence the OECD’s digital tax rules

    July 22, 2019

    As countries consider the OECD’s digital tax proposals, tax heads shared their experiences of trying to get their voices heard.

  • G7 leaders push ahead with global minimum tax

    July 19, 2019

    The finance ministers of the G7 countries have agreed that a global minimum tax should be introduced to ensure companies like Facebook and Amazon pay ‘their fair share of tax’.

  • Survey results: Untangling CFC structures

    July 15, 2019

    Multinational businesses are simplifying structures to navigate the rules that target controlled foreign corporations (CFCs) and their shareholders. ITR asked those tax heads who have adopted this approach to share their business’s operational changes.

  • Cryptocurrency, cost basis and taxation

    July 15, 2019

    Cryptocurrencies are still capturing the attention of investors, traders and enterprises around the globe, lauded for their potential as a radically transformative force on the existing financial playing field. However, legal systems are yet to catch up.

  • Market insight: People moves

    July 10, 2019

    In this month’s round-up of individual and company changes, Andersen Global expanded into the Middle East, while several tax teams in Central America grew and a number of lead partners were appointed to major firms worldwide.

  • Global minimum taxation: A matter of time

    July 10, 2019

    Minimum tax red flags have appeared in recent legislation as countries and organisations race to address perceived inequities within the international tax regime.

  • Companies measure tax departments on their ability to cut risk, not effective tax rates

    July 10, 2019

    Managing tax risk is the most important metric by which tax departments are measured, with the more traditional target of lowering the company’s effective tax rate being less important to tax heads. However, CEOs seem to know little about tax KPIs and how, or why, they are chosen.

  • Businesses disappointed with OECD’s digital tax progress

    July 10, 2019

    As G20 countries ratify the OECD’s work on taxing the digital economy, tax executives expressed their concern to International Tax Review that the body has not moved beyond proposals that they find problematic.

  • US companies fear TCJA amendments by Democrats

    July 10, 2019

    Some US taxpayers are considering inversions because they fear negative tax implications if the Democrats gain control of the presidency and Congress in the 2020 elections and raise the corporate tax rate.

  • Tax Advisory Survey 2019

    July 10, 2019

    Tax and trade wars among governments and the battles companies face against tax authorities through audits and inevitable disputes mean even the most super-human tax director among us needs a little help.

  • Only one way out: Simplifying CFC regimes

    July 10, 2019

    The number of countries adopting controlled foreign corporation (CFC) regimes has complicated business operations and forced them to change. Danish Mehboob talks to taxpayers who are trying to avoid getting lost in the labyrinth of multiple tax risks and unexpected audits.

  • Tax heads encourage more companies to use ICAP

    July 10, 2019

    Tax leaders from Barilla, Repsol and Shell have encouraged their contemporaries to sign up for the International Compliance Assurance Programme (ICAP), before the window to get involved closes later this month.

  • Case study: Shell’s participation in ICAP

    July 10, 2019

    Danny Houben, project lead for Shell’s ICAP team, talks to International Tax Review about how his company got ready to participate in the OECD’s International Compliance Assurance Programme (ICAP).

  • Case study: Repsol’s participation in ICAP

    July 10, 2019

    Rocío Bermúdez, tax global practices & transfer pricing senior manager at Repsol, spoke to ITR about her company’s participation in the first pilot of the International Compliance Assurance Programme.

  • The negative aspects of ICAP

    July 10, 2019

    While feedback on the International Compliance Assurance Programme (ICAP) has been overwhelmingly positive, unsurprisingly, the first pilot did encounter some teething problems.

  • OECD won’t rush ICAP expansion despite scheme’s popularity

    July 10, 2019

    The OECD’s Achim Pross says his ultimate aim is to expand the International Compliance Assurance Programme (ICAP), but companies may be disappointed to learn that it could be a relatively slow process.

  • Tax transformation: What companies need to know

    July 10, 2019

    In a wide-ranging interview, ITR speaks to Terri LaRae, partner and leader of the global operations transformation tax team at Deloitte, about the factors driving tax transformation and how tax departments can get the best out of it.

  • US: Sale of a partnership interest: Withholding tax

    July 10, 2019

    The US Treasury and the Internal Revenue Service (IRS) have proposed withholding tax regulations regarding the Tax Cuts and Jobs Act (TCJA) provisions, addressing sales of interests in partnerships engaged in the conduct of a US trade or business.

  • How concerned should companies be about data they send to tax authorities becoming public?

    July 10, 2019

    It’s interesting that the subject of data submitted to the tax authorities becoming public, either through a data leak or public country-by-country reporting (CbCR), is clearly still a significant concern among tax directors.

  • DAC6 fixes tax loopholes but confuses taxpayers

    July 08, 2019

    Banks are confused about how to follow the ‘vague hallmarks’ in the EU mandatory disclosure regime (DAC6).

  • Silicon Valley’s leading women in tax tackle ‘world peace’

    July 05, 2019

    Finding a solution to taxing the digital economy and getting international agreement could win the OECD the tax equivalent of the Nobel Peace Prize, but thankfully being a female tax leader is easier to achieve, according to speakers and attendees at ITR’s Leading Women in Tax Forum in Palo Alto, US.

  • Facebook ups the ante for global cryptocurrency tax framework

    July 03, 2019

    The launch of Facebook’s Libra currency and discussions at the G20 Summit about financial fraud and tax evasion with digital assets has ‘lit a fire under policymakers’ to develop better regulatory responses.

  • June 2019

    KPMG US settles PCAOB case for $50 million

    June 18, 2019

    KPMG has agreed to pay out as much as $50 million to settle civil claims against former employees who allegedly leaked information from the Public Company Accounting Oversight Board (PCAOB).

  • ‘The hunt is on’ to find aggressive structures that work

    June 17, 2019

    While most companies are moving away from aggressive tax planning, some in-house tax directors say they are still looking for new structures to reduce their effective tax rate (ETR).

  • Tax professionals: it is time to change the global corporate tax rules

    June 14, 2019

    Tax chiefs have used International Tax Review’s survey on the taxation of the digital economy to say that international corporate tax rules are not working – but are divided on what should replace them.

  • Euromoney LMG Americas Women in Business Law Awards 2019 – winners announced

    June 07, 2019

    The best women lawyers in the Americas gathered at the JW Marriott Essex House hotel in New York to celebrate the achievements of women across firms, practice areas and jurisdictions.

  • J5 cyber tax crime unit investigating global financial institution

    June 05, 2019

    Data scientists and criminal investigators from the Joint Chiefs of Global Tax Enforcement initiative, or the J5, are involved in more than 50 investigations concerning sophisticated international enablers of tax evasion, including one global financial institution and its intermediaries.

  • Tax modelling failing to determine global tax risks effectively

    June 03, 2019

    Tax chiefs at Repsol and Baker Hughes said modelling the tax risks across their CFC networks has increased in importance since the BEPS measures were finalised, but a lack of trust in the results and rising compliance costs impede enhancements to tax modelling.

  • May 2019

    OECD to consider worldwide fractional apportionment

    May 31, 2019

    The OECD’s Inclusive Framework countries have agreed to a 40-page report that outlines potential ways to tax the digital economy. The document suggests, among other measures, introducing worldwide fractional apportionment for corporate profits.

  • Tax departments aren’t getting the best out of business analysts

    May 28, 2019

    Tax technology leaders worry business analysts’ lack of deeper tax knowledge stops them from letting the rest of the business know about their roles in tackling tax challenges.

  • Foreign investors pressure young US businesses into inversions

    May 28, 2019

    The US Tax Cuts & Jobs Act (TCJA) is failing to prevent inversions, with the lure of foreign capital often outweighing the tax challenges that rapidly expanding businesses face.

  • Johnson & Johnson’s Amos discusses her BEPS 2.0 proposal

    May 28, 2019

    The tax director who stunned participants at the OECD’s digital tax consultation with a fleshed-out proposal for formulary apportionment of corporate profits speaks to Alexander Hartley in an exclusive interview.

  • Intangibles: Re-engineering substance

    May 28, 2019

    The BEPS project has had a fundamental impact on how multinational companies are structuring their intangible assets. Josh White investigates how businesses are reorganising their tax arrangements to meet their commercial needs

  • Exercising judgement as the head of tax

    May 28, 2019

    Heads of tax are called upon to make decisions continually, ranging from routine choices to the less frequent, but materially significant. Making decisions involves a combination of exercising judgement and drawing on structured processes to reduce risk writes Sandy Markwick, head of the Tax Director Network at Winmark.

  • Blockchain case study: A way to speed up Mexico’s tax refunds

    May 28, 2019

    Could Mexico’s tax authorities have avoided legal action from businesses looking for compensation over slow tax refunds by replacing legacy reporting systems with blockchain technology? Danish Mehboob investigates.

  • SEC filings show US MNE uncertainty over long-term impact of TCJA

    May 23, 2019

    Financial reports show businesses such as Target and JPMorgan Chase lowering their effective tax rates, but they remain uncertain about the long-term impact of US tax reform, which has limited corporate planning and restructuring.

  • US tax experts: Platforms must expect to collect sales tax

    May 20, 2019

    Although federal legal precedent is yet to be established, a liability on platform providers to collect sales tax is rapidly becoming the de facto law of the land, experts told International Tax Review.

  • Reorganisations slow amid vague indirect transfer tax regimes

    May 16, 2019

    Uncertainty over how to tax offshore indirect transfers and delay to establishing an international framework for taxing such transfers is leading to a slowdown in corporate reorganisations.

  • Taxpayers caught up in CFC state aid ruling expect UK to appeal

    May 13, 2019

    Companies such as the Daily Mail Group, Diageo and the London Stock Exchange are expecting the UK to appeal the EU’s state aid decision against the country’s CFC group financing regulation, but there is very little time to file a challenge.

  • Companies see user participation as a nightmare

    May 08, 2019

    Tax professionals are worried about how to identify user participation accurately within any digital business model, particularly given how easy it is for users to hide their true location.

  • MNEs gain tax certainity through document standardisation

    May 03, 2019

    Tax directors are dealing with more audits, but standardising global tax operations can greatly ease the burden because it helps tax authorities understand corporate tax positions better.

  • Taxpayers say a sabbatical on BEPS would be a good thing

    May 01, 2019

    Tax directors have criticised a post-BEPS environment for emboldening less experienced, less technically-knowledgeable tax authorities to start transfer pricing audits based on “unsound arguments” to crack down on aggressive tax planning.

  • April 2019

    General Atlantic hires GE head of tax

    April 25, 2019

    After many years at the US energy multinational, Michael Gosk has taken on the role of operating partner at global growth equity firm General Atlantic.

  • Do tech companies hold the solution to taxing the digital economy?

    April 24, 2019

    The digital revolution has transformed business models, entire economies and the lives of people around the globe. It has also tested the concept of traditional corporate tax rules, designed largely in the first half of the 20th century. These rules are now unfit for our increasingly digitalised and globalised world.

  • Norton Rose Fulbright hires tax partner in New York

    April 22, 2019

    Norton Rose Fulbright has appointed David Burton as a renewable energy tax partner to help global clients with finance and energy transactions.

  • McCarthy Tétrault hires Raj Juneja in Toronto

    April 19, 2019

    McCarthy Tétrault has hired Raj Juneja as an equity partner to its transactional and tax advisory practice in Toronto.

  • Blackstone restructures as corporation after TCJA

    April 18, 2019

    Following US tax reform, Blackstone has decided to give up its complex partnership structure to reduce its tax compliance burden and make its stock more attractive to investors. However, it will likely cost the company more in taxes.

  • US loophole allows tax-efficient trading via ETFs

    April 15, 2019

    A loophole left open by the US government following tax reform means exchange-traded fund (ETF) investors can make tax savings through so-called ‘heartbeats’ trading with the help of investment banks and large trading firms.

  • ERP systems preferred over tax engines to determine tax payments

    April 15, 2019

    Tax directors explain why they prefer ERP system customisations over tax engines to help them automatically determine their tax liabilities despite both options having their fair share of problems.

  • Uber admits fear of new tax liabilities in IPO filing

    April 12, 2019

    In its prospectus to potential investors, Uber has expressed fears of becoming subject to much higher indirect and payroll taxes if governments decide it is a transportation company.

  • Investors want a global standard for MNE tax disclosures

    April 10, 2019

    Investors are using multinational companies’ tax disclosures, such as country-by-country reports, to inform their investment decisions – and want consistent disclosure formats to make comparisons easier.

  • ITR Americas Tax Awards 2019: Submit now

    April 10, 2019

    International Tax Review is now accepting submissions for the 2019 Americas Tax Awards.

  • Norton Rose Fulbright hires tax partner in London

    April 09, 2019

    Norton Rose Fulbright’s London practice has hired Michael Alliston, a corporate tax specialist, as a partner.

  • Andersen Tax debuts in Greece and Cyprus

    April 05, 2019

    Andersen Global has continued its expansion throughout Europe with Unity Four and Pistiolis-Triantafyllos & Associates taking on the brand name.

  • GRI’s tax initiative threatens to overtake CbCR on tax transparency

    April 05, 2019

    Tax directors are backing an independent standard-setting body, the Global Reporting Initiative (GRI), to introduce a worldwide standard to tax reporting and public disclosures, but many worry that the standard will clash with country-by-country reporting (CbCR).

  • Media companies support digital taxation proposals

    April 05, 2019

    Media-related businesses are united in their desire to ‘level the playing field’ on taxing traditional and digital companies, but they do not all agree on the best way forward.

  • Platforms to OECD participants: Please don’t pick on us

    April 04, 2019

    In responses to the OECD’s digital taxation consultation, online platform providers including Uber and Spotify expressed fear of being singled out and subjected to stiffer treatment than conventional businesses.

  • Tax Disputes Summit: Meet the speakers

    April 03, 2019

    Tax leaders from Acer, H&M, Swiss Re, the Portuguese Centre for Administrative Arbitration, the Finnish and Danish tax authorities, White & Case and William Fry speak to International Tax Review about trends, predictions and what is keeping them busy ahead of the ITR Tax Disputes Summit.

  • The world’s best tax transactional firms 2019

    April 03, 2019

    International Tax Review presents key trends and developments in the tax transactional market and ranks the best firms to help companies navigate the post-BEPS environment that poses challenges in restructuring and mergers and acquisitions.

  • David Fruchtman joins Steptoe’s tax group in New York

    April 02, 2019

    Steptoe & Johnson has appointed David Fruchtman as partner in the firm’s tax group in the US.

  • Survey: Untangling CFC rules and regimes

    April 01, 2019

    Companies have to navigate a web of differing rules targeting controlled foreign corporations (CFCs) and their shareholders, but the process is far from easy when the distinctions in each country’s rules risk unexpected audits or an unreasonably high tax burden.

  • Tom West joins KPMG in Washington

    April 01, 2019

    Tom West has moved from his role as tax legislative counsel at the US Treasury’s office of tax policy to join KPMG as principal in the Washington national tax practice’s passthroughs group.

  • March 2019

    Tax technologists increasingly important but hard to find for MNEs

    March 21, 2019

    Demand for tax technologists is rising in the post-BEPS environment, according to tax and technology leaders, as tax departments find it increasingly important to prepare systems for new developments coming from tax authorities.

  • Bigger-than-expected Chinese VAT cuts lead to speculation on reform

    March 21, 2019

  • Exclusive: US state drags Amazon to court on platform sales tax liability

    March 21, 2019

  • MNEs take legal action to expedite tax returns in Mexico

    March 21, 2019

  • Stepping up: Companies get into the stride of post-BEPS tax transactions

    March 21, 2019

    After a buoyant start to 2018, M&A activity tailed off in the final quarter of the year. Despite this, for transactional tax, many large companies are restructuring as they adjust to the US Tax Cuts and Jobs Act, post-BEPS rules such as the EU Anti-Tax Avoidance Directive, and to the new reality of the digital economy.

  • Government and customers – the driving force of digitisation

    March 21, 2019

    Kim Hau, senior proposition manager for ONESOURCE Indirect Tax at Thomson Reuters, explains why corporate indirect tax teams must shift their approach from ‘surviving’ the compliance cycle to a more proactive and considered way of working.

  • France to push G7 countries for a global minimum corporate tax

    March 21, 2019

    France plans to make significant progress with members of the G7 group of countries to reach an agreement on a minimum corporate tax rate, after the OECD has presented its work on taxing the digital economy to the G20 in June.

  • US tax reform turns into a game of ‘whack-a-mole’

    March 15, 2019

    For global corporations, determining how to comply with the US tax reform provisions and manage tax liabilities is difficult because as soon they resolve one tax problem, another pops up.

  • Consumer businesses clash over OECD digital tax proposals

    March 14, 2019

    MNEs specialising in consumer products prefer to ‘cherry-pick’ provisions they favour from the OECD’s digital tax proposals, creating a conflict among them on the best approach to taxing the digital economy.

  • Mark Rems joins KPMG US

    March 14, 2019

    Mark Rems has joined KPMG’s US state and local tax (SALT) practice as a principal in Philadelphia. He will be a part of the firm’s indirect tax practice and focus on transaction tax systems.

  • MNEs accept higher tax burden is inevitable at OECD digital tax consultation

    March 14, 2019

    Corporate tax heads at the OECD digital tax consultation in Paris admitted that they would need to bow to political pressure and accept potentially painful reforms.

  • Kene Partners appoints two to R&D-focused tax practice

    March 14, 2019

    Aarti Varia and Rosie Silk have joined Kene Partners in London to specialise in research and development (R&D) within the consultancy team as R&D tax director and R&D tax manager, respectively.

  • Women in tax explain how to deal with gender stereotyping

    March 08, 2019

    Leading women in tax share their personal experiences and the resistance they overcame at the beginning of their careers to succeed, offering tips to aspiring leaders.

  • Tax directors pushed into aggressive tax tactics as authorities lose funding

    March 04, 2019

    Corporate tax departments are under pressure to find aggressive ways of reducing their effective rates that exploit under-resourced tax authorities.

  • Seth Entin joins Holland & Knight in the US

    March 01, 2019

    Holland & Knight has hired Seth Entin as an equity partner to advise clients in private wealth services in the Miami office.

  • February 2019

    Controversial border-adjustment tax survives in US TCJA

    February 28, 2019

    Paul Nylen, assistant professor of tax at the University of Wisconsin – Whitewater, explains how the US government has managed to include the divisive border adjustment tax (BAT) in the US Tax Cuts and Jobs Act (TCJA) and what it means for taxpayers globally.

  • Barbara Angus becomes EY global tax policy leader

    February 21, 2019

    Barbara Angus, a key figure in drafting the US Tax Cuts and Jobs Act (TJCA), has been appointed global tax policy leader at EY.

  • Survey: Effective TP management of global intellectual property

    February 19, 2019

    Multinational companies face the challenge of how to restructure their intellectual property (IP) in an increasingly uncertain world. Taxpayers can voice their concerns anonymously in International Tax Review’s IP survey.

  • Baker Botts elects John Martin as next managing partner

    February 19, 2019

    John Martin has been elected as managing partner at Baker Botts,, and will commence his four-year term on April 1 2019.

  • Baker McKenzie hires new tax counsel in Dallas

    February 18, 2019

    Christopher Hanna has joined Baker McKenzie’s tax policy team to help clients navigate the 2017 US tax reform rules in the areas of tax planning, global structures, intellectual property, and supply chains.

  • ‘Over 50 shades of grey’ in corporate taxes make automation tough

    February 18, 2019

    Finding consistency in direct tax and transfer pricing matters makes it increasingly challenging to automate repetitive or routine tasks in the global tax function, say tax technology leaders.

  • Howard Wiener becomes KPMG’s US principal in charge in London

    February 15, 2019

    KPMG US has named Howard Wiener as principal in charge of its US tax practice based in London.

  • The OECD’s four proposals to tax the digital economy

    February 14, 2019

    The leading proposal in the OECD’s two-week consultation on four possible approaches to taxing the digital economy focuses on marketing intangibles, expanding the number of businesses that could fall under its scope.

  • CbCR: MNEs invest more in tech and personnel to address audit risks

    February 12, 2019

    Tax heads are spending millions on new technology and staff to deal with what can be unfair audits by tax authorities looking at county-by-country reports (CbCR), adding data to what is already an increasingly dispute-prone environment.

  • Submit now for World Tax and World TP 2020

    February 11, 2019

    We are pleased to announce the official launch of World Tax and World TP 2020.

  • Skills exchange helps tax teams succeed with digital reporting

    February 11, 2019

    Tax departments are partnering with other corporate functions to obtain the skills required to comply with technology-driven tax policies as they try to find a way around limited budgets and resources.

  • Falling tax rates only one part of incentivising business investment

    February 06, 2019

    Corporate tax rates continue to fall due to increasing cross-border competition through tax reform, but tax heads have more to consider when investing overseas than just rates.

  • Why BEPS 2.0 makes tax heads nervous

    February 04, 2019

    Some tax directors are unimpressed by the direction of the OECD’s digital tax proposals, with one warning they will bring “a whole new world” with wide-ranging implications.

  • Automation challenges under varying SAF-T frameworks

    February 04, 2019

    Multinationals are being forced to implement complex automated solutions to comply with the differing reporting frameworks across Europe because local tax authorities are more focused on tackling VAT fraud than the increasing compliance costs.

  • Investor pressure drives corporate tax policy development

    February 01, 2019

    Investors are giving serious consideration to their targets’ corporate tax policies before agreeing on the deal, but there are a number of companies that still have no such policy in place.

  • Tax directors explain the importance of data modelling

    February 01, 2019

    Businesses are increasingly using data modelling to more accurately determine their tax liabilities and prove their compliance to tax authorities amid the political pressures that are constantly changing the goal posts.

  • January 2019

    Cryptoassets: UK and US approach transactions in similar manner

    January 29, 2019

    The UK’s tax authority, HM Revenue and Customs (HMRC), has recently published updated guidance on the tax treatment of cryptoassets. Kate Habershon, Neil McKnight and Nelson Yates II of Morgan, Lewis & Bockius examine the guidance and how it compares to the US’s perspective.

  • Baker Botts hires Jon Feldhammer as partner in San Francisco

    January 28, 2019

    Jon Feldhammer has joined Baker Botts’s San Francisco office as a tax litigation partner.

  • Who controls the digital tax debate?

    January 28, 2019

    Businesses shouldn’t think about compliance with EU digital tax proposals, but instead influence the conversation and ensure governments aren’t hitting them by accident, say tax executives, advisors and lobby groups.

  • The future perspective on the FDII and BEAT

    January 28, 2019

    Keith Brockman, VP of global tax at Manitowoc Foodservice, explores how the World Trade Organisation could influence the US foreign-derived intangible income (FDII) regime, base erosion and anti-abuse tax (BEAT), and global intangible low-taxed intangible income (GILTI) provisions.

  • Tax heads: A global standard is essential for blockchain adoption

    January 28, 2019

    Tax directors examining tax technology opportunities know that regulating internal data and establishing a global reporting standard is a must when it comes to the successful cross-border adoption of any digital platform. Blockchain is no different.

  • The biggest US states are getting serious about Wayfair

    January 28, 2019

    For all companies that sell to US consumers without a physical presence in states, 2018’s Wayfair decision was a bolt from the blue. But the work of complying with ‘economic nexus’ rules in every taxing jurisdiction will be an ongoing project, not a one-off effort.

  • Financial institutions adapt to tax transparency

    January 28, 2019

    Tax transparency initiatives such as the CRS, AEOI and FATCA, and the upcoming mandatory disclosure rules, are having a profound impact on the operations and IT infrastructure of financial institutions (FIs) worldwide. Ronald Frey, chief product officer of the RegTech product unit within BearingPoint, discusses how these are creating trends towards data alignment and centralisation, and are changing the role of FIs and wealth managers in cross-border tax reporting.

  • The battle for resources: Making the case for tax departments

    January 28, 2019

    The rate of change in the tax regulatory environment in recent years has been rapid, arguably more so than at any other time in recent history. Heads of tax are competing with colleagues in other functions for a share of finite budgets. The challenge is to show value for money, writes Sandy Markwick, head of the Tax Director Network at Winmark.

  • 2019: The eye of the storm

    January 28, 2019

    After several years of rapid change, the international tax system appears to be entering a calmer phase, but the outlook suggests that some big challenges are on the horizon. Josh White looks at the 2019 forecast.

  • A practical guide for operational transfer pricing excellence

    January 28, 2019

    A well-constructed and executed global operational transfer pricing (OTP) framework is essential to properly manage financial statements, taxes and reputational risk for multinational enterprises (MNEs), writes Richard Goldberg, former tax director at Mitsubishi Financial Group.

  • Not another tax department transformation

    January 28, 2019

    One of the principal subjects of discussion and analysis in tax in recent months is digitalisation. I am not only talking about the OECD, EU and unilateral proposals to address the taxation of the digital, or digitalised, economy, but also the potential of digital innovations to change business, tax administration and tax department processes.

  • REITs on the rise under Trump’s tax cuts

    January 28, 2019

    Advisors and fund managers expect more qualified opportunity funds (QOFs) to be organised as real estate investment trusts (REITs) to maintain key US tax benefits under the TCJA's qualified opportunity zone (QOZ) programme and avoid locking in investments.

  • Platforms: Where the real Wayfair money is

    January 23, 2019

    Collecting sales tax from online platforms like eBay and Amazon presents US states with a big cash prize and a host of technical complications. Vendors should beware of being caught between the states and the money.

  • Upcoming US 10K filings to offer clues to BEAT and GILTI compliance

    January 22, 2019

    Banks will be examining the February 10K filings of their competitors to see how they are dealing with the BEAT and GILTI provisions in the US Tax Cuts and Jobs Act (TCJA).

  • Weil, Gotshal & Manges hires partner in Washington, DC

    January 08, 2019

    Devon Bodoh has joined the firm as a tax partner and will head the firm’s international and cross-border tax practice.

  • What the G20 should know about international cryptocurrency tax policy

    January 07, 2019

    International cryptocurrency tax policy can achieve trust if it is done correctly, writes Michael Minihan, partner at BX3 Capital.

  • How to build an in-house team to take on technological advancements

    January 04, 2019

    Tax heads at multinational enterprises share insights on how to build digitally-focused teams to meet real-time compliance obligations and reduce business costs.

  • Joseph Pari appointed co-chair of Weil’s global tax department

    January 03, 2019

    The experienced tax lawyer will be based in the firm’s Washington, DC, and New York offices.

  • Loyens & Loeff promotes Michiel Schul to partner

    January 03, 2019

    Michiel Schul has become a partner at the firm’s Amsterdam office as of January 1 2019.

International Correspondents