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Ireland Announces the End to the “Double Irish” Tax Structure

A tax structure often referred to as the “Double Irish” is being shut down by the Irish government, although companies that are currently utilizing the structure will have a five-year transition period before the new law eliminates the tax structure completely. Finance Minister Michael Noonan announced that Ireland’s 2015 budget is “abolishing the ability of companies to...

OECD Releases Digital Economy Discussion Draft: Few Surprises–No Conclusions

On March 24th, the Organisation for Economic Cooperation and Development (OECD) released its discussion draft on e-commerce, as part of its base erosion and profit shifting (BEPS) project.  The draft is a result of BEPS Action 1: address the tax challenges of the digital economy. After 58 pages describing the digital economy and the tax challenges it presents, the discussion draft...

OECD Releases Discussion Draft on Treaty Abuse

On March 14, the Organisation for Economic Cooperation and Development (OECD) released a public discussion draft on Action 6 of its Base Erosion and Profit Shifting (BEPS) project, on how to prevent treaty abuse.  The discussion draft covers many issues, but five key recommendations stand out.  The first four are changes to the OECD Model Tax Convention itself (the “Model...

OECD Goes 2-for-2: Releases Two Discussion Drafts on Action 2

The Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) action plan is moving forward.  On March 19, 2014, the Organisation for Economic Co-operation and Development (OECD) released two discussion drafts on “action 2” of the OECD’s BEPS action plan (Action 2). Action 2 is targeted at neutralizing the potential tax advantages,...

OECD’s BEPS Hybrid Draft Tells Rest of Europe to be More Like Germany

The OECD’s Base Erosion and Profit Shifting (BEPS) project continues apace, and information on the direction of the project is getting out.  On February 10, Tax Analysts’ Lee Sheppard reported on a leaked draft report dealing with hybrid entities (entities which are treated as separate entities in one jurisdiction but are disregarded as separate entities or treated as pass-through...

OECD Meets With Business Representatives on BEPS Action Plan

As the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project moves forward, global businesses are making sure their opinions are taken into account.  Recently, OECD officials held a “business dialogue” with representatives of the business community, organized by the Business and Industry Advisory Committee (BIAC) to...

Former Treasury Official Questions Camp’s Option C; Urges Greater U.S. Participation in BEPS Discussions

Speaking last week on the centennial of the U.S. income tax, Harvard Law School professor and former deputy assistant secretary of the Treasury Stephen E. Shay criticized House Ways and Means Committee Chairman Dave Camp’s proposal to address base erosion and profit shifting (BEPS).  Called “Option C,” Rep. Camp’s proposal would adopt a territorial tax system and reduce the...

G20 Leaders Endorse BEPS Action Plan, Promise to Tackle Tax Avoidance

In a declaration issued at the end of last week’s St. Petersburg summit, G20 leaders stated that they “fully endorse” the Organisation for Economic Cooperation and Development’s (OECD) ambitious action plan for tackling base erosion and profit shifting (BEPS) and reforming the international tax system.  G20 leaders called on members to examine how their own tax systems...

BEPS Plan on the Agenda at the G20 Summit

Leaders attending the September 5-6 G20 Summit in St. Petersburg, Russia, are expected to discuss international tax reform, including the Organisation for Economic Co-operation and Development (OECD) action plan for addressing base erosion and profit shifting (the BEPS plan).  The BEPS plan, which was produced at the request of the G20, focuses on transfer pricing, permanent...

Growing Concerns Over “Stateless Income” Make It a Target for International Tax Reform

Tax planning of multinational corporations designed to generate what is being referred to as “stateless income”—income sourced in low-tax jurisdictions or in no source country at all— continues to be scrutinized both in the United States and abroad.  Senator Carl Levin (D-MI), a major proponent of tax reform, has held Congressional hearings over the past several months on the...

OECD Unveils Action Plan, G20 Expected to Endorse It

The Organisation for Economic Co-operation and Development (OECD) has unveiled its long-awaited plan for reforming the international tax system. The OECD presented its “Action Plan on Base Erosion and Profit Shifting” to the G20 finance ministers at their meeting in Moscow. The plan is aimed at curtailing profit shifting from high-tax to low-tax jurisdictions by...

Conflicts Over Tax Rates – It’s Not Just for Havens Anymore

Germany has called upon the EU to ban the low rates offered by EU competitors, but instead of targeting the small low-tax jurisdictions, this issue is aimed at Europe’s 3rd largest economy – the UK. The German finance minister, Wolfgang Schaeuble, wants the EU to ban the “patent box” regimes that the UK and some other EU countries have in place to attract investments in research...

Camp Shows Support for a Flat Tax Rate on Foreign Intangibles Income

At a hearing last week on tax havens, base erosion and profit shifting, House Ways and Means Committee Chairman Dave Camp stated that “revenue erosion” would be limited by imposing a 15% flat tax on all foreign income from intellectual property rights and intangibles. Rep. Camp’s proposal would provide a deduction for income related to intangibles kept in the U.S. but also...

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