The IRS released final and proposed regulations providing further guidance and addressing certain open issues under the base erosion and anti-abuse tax (BEAT). The final regulations, based partly on the IRS’s response to comments received, clarify previously proposed regulations, such as providing that certain amounts transferred in connection with a nonrecognition transaction are not base erosion payments. The newly proposed regulations would create a mechanism to reduce or eliminate application of the BEAT rules […]
The Organisation for Economic Cooperation and Development (OECD) Secretariat has released an approach to address what it has termed the “tax challenges of the digitialisation of the economy.” The approach builds upon the Program of Work released on May 28, 2019, by the Inclusive Framework on Base Erosion and Profit Shifting (BEPS). Following consultations and input from interested parties, the OECD Secretariat developed what it calls the “Unified Approach” and which it hopes will be […]
Given the disruption in world order evidenced by recent elections, civil wars, mass protests and Brexit, perhaps it is not surprising that this is a time of great change in international taxation as well.
Countries have become alarmed that the nature of Internet business seems to be eroding many countries’ tax bases. Digital giants such as Google and Facebook, almost all of which are U.S. companies, are paying little tax despite having users that number […]