Podcasts about base erosion

This Tax Section Odyssey podcast episode takes a deeper dive into the Organisation for Economic Co-operation and Development's (OECD) initiative on Base Erosion Profit Sharing (BEPS) 2.0 which sets to reform the internation tax system with Pillar 1 and 2 tax regimes. In addition to the complexity of such international regulations, the political landscape for U.S. implementation is uncertain, and potential action is needed from Congress. Cory Perry, Principal, National Tax — Grant Thorton Advisors, and Vice Chair of the AICPA's International Technical Resource Panel (TRP), highlights that while many U.S. companies may not face larger tax bills if these regimes are adopted in the U.S., the administrative and compliance challenges are significant. The AICPA has submitted comment letters to the OECD, Treasury, and the IRS, focusing on simplification and clarification of rules. AICPA resources OECD BEPS 2.0 - Pillar One and Pillar Two — The OECD BEPS 2.0 sets out to provide a tax reform framework allowing for more transparency in the global tax environment. What you need to know about BEPS 2.0: Pillar One and Pillar Two | Tax Section Odyssey — The OECD BEPS 2.0 project is an international effort to reform the international tax system that addresses transfer pricing, profit allocation and tax avoidance. Advocacy Comments to Treasury on tax issues of OECD Pillar Two, Feb. 14, 2024 Comments to Treasury on Amount B of OECD Pillar One, Dec. 12, 2023  Other resources OECD BEPS — Inclusive Framework on Base Erosion and Profit Sharing For a full transcript of the episode, see  Tax Section Odyssey on the AICPA & CIMA website. 

The OECD BEPS 2.0 project consists of two pillars. Pillar One applies to the biggest and most profitable multinational enterprises and reallocates part of their profit and taxing rights to the countries where they sell their products and services. Pillar Two introduces a global minimum corporate tax of 15% to prevent tax avoidance and base erosion.   The U.S. has not yet adopted the OECD project into its tax system, but it will still impact U.S. multinational businesses that operate abroad. Practitioners need to know about the OECD project because it is a major change in the international tax system that will affect many multinational enterprises and their tax compliance.   AICPA resources OECD BEPS 2.0 - Pillar One and Pillar Two — The OECD BEPS 2.0 sets out to provide a tax reform framework allowing for more transparency in the global tax environment. Advocacy Comments to Treasury on tax issues of OECD Pillar Two, Feb. 14, 2024 Comments to Treasury on Amount B of OECD Pillar One, Dec. 12, 2023 Other resources  OECD BEPS – Inclusive Framework on Base Erosion and Profit Sharing

This week, Conan D'Arcy is joined by Senior Associate Russell Lamb to explore how the global community is tackling the taxation of large digital companies. The OECD has spearheaded negotiations for over a decade on how to combat the issue of Base Erosion and Profit Shifting (BEPS), but ahead of a critical year-end deadline, are the talks losing steam? Conan and Russell discuss the underlying geopolitics and what might lie ahead for both businesses and governments. Hosted on Acast. See acast.com/privacy for more information.

In this episode, Marna Ricker, Global Vice Chair -- Tax at EY joins us from the Milken Institute Global Conference 2003 to discuss the global tax landscape. We get Marna's perspective on the OECD's Base Erosion and Profit Shifting Project, the TCJA, and how AI might affect the world of tax practice.

Nigeria has opted out of a global tax deal negotiated under the Organisation of Economic Cooperation and Development G20 Inclusive Framework on Base Erosion and Profit Shifting. The OECD estimates that countries lose $100-$240 billion worth of revenue annually to BEPS practices, which is the equivalent to 4-10 per cent of the global corporate income tax revenue. The Global Financial Integrity stated that the framework represents a group of countries and jurisdictions working together to address systemic issues within the global taxation system that cause an inequitable distribution of tax revenues among countries and jurisdictions.

The OECD's Inclusive Framework on Base Erosion and Profit Shifting is aiming to help developing countries implement a global agreement to change how multinational companies are taxed, according to the co-chair of its steering committee. The agreement, which more than 130 countries signed up to in October, has two pillars. Pillar One reallocates a portion of the largest multinationals' profits to market jurisdictions, while Pillar Two creates a global minimum tax rate of 15%. The two pillars come with enormous complexities, meaning some countries will need help to keep up with the pace of implementation, says Marlene Nembhard-Parker, chief tax counsel for legislation, treaties, and international tax matters at Tax Administration Jamaica and co-chair of the Inclusive Framework Steering Group. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Scott and Jeff discuss the OECD's Base Erosion and Profit Shifting (BEPS) project with Tom Neubig, a former Economist with the OECD. We answer basic questions about the OECD, BEPS, Pillar One and Pillar Two, which includes the proposed global minimum tax. The project is designed to stop the "race to the bottom" and to prevent large multinational companies from shifting their income to low-tax jurisdictions like tax havens. We also briefly discuss how country by country reporting will help with analysis after implementation.

This GCP Short, produced in collaboration with EY, outlines how the OECD's latest work on Base Erosion and Profit Shifting (Beps) may impact Singapore and the captives domiciled there, as well as discussing captive trends in Japan. Richard is joined by Adrian Halter, a Financial Services and Tax Partner based in Singapore and a member of EY's Global Captive Network, and then James Littlewood, a Partner in Client Services for EY Strategy and Consulting, based in Japan. For more information on EY, visit their Friend of the Podcast page: https://www.globalcaptivepodcast.com/ey For more information on the the Asian Captive Conference 2021, hosted by Labuan IBFC, visit here: https://www.labuanibfc.com/events/upcoming-events/labuan-ibfc-inc/the-asian-captive-conference-2021-virtual-conference Read the third edition of GCP Insights here: www.globalcaptivepodcast.com/gcp-insights You can subscribe to the Global Captive Podcast on iTunes, Apple Podcasts, Spotify or any other podcast app. Contact Richard: richard@globalcaptivepodcast.com Visit the website: www.globalcaptivepodcast.com Follow us on LinkedIn: www.linkedin.com/company/global-captive-podcast/

Doug McHoney (PwC's US International Tax Services (ITS) Leader) holds the second post-vaccine session live at the Westminster Studios with Pat Brown (PwC WNTS Policy Co-leader) to discuss President Biden's FY 22 Budget and the much anticipated and related explanations of such proposals, also known as the Treasury Green Book. Doug and Pat cover, among other proposals: increasing the US corporate income tax rate from 21% to 28%; increasing the global intangible low-taxed income (GILTI) tax rate to 21%; removing the qualified business asset investment (QBAI) provision; repealing the deduction for foreign derived intangible income (FDII); replacing the Base Erosion and Anti-Abuse Tax (BEAT) with a Stopping Harmful Inversions and Ending Low-tax Developments (SHIELD) provision; restricting deductions of excessive interest for disproportionate borrowing in the US; the status and likelihood of the OECD's Pillars One and Two; and what companies should consider as potential tax legislation becomes more likely.

Globalisation has brought major benefits for businesses, but at the same time it has enabled large multinational firms to book their profits in countries with low or no tax, rather than where they carry out their business activity. Governments lose out because shifting profits in this way can erode the tax base. Moreover, the digital economy adds to the challenge of working out how much international companies owe in tax and to which countries, in part because digital firms may not have a physical presence in the places they do business in. The OECD, which launched the Base Erosion and Profit Shifting (BEPS) initiative in 2013, has been leading international talks to address these issues, and is aiming towards a landmark agreement on new tax rules in 2021. Grace Perez-Navarro, deputy director of the OECD Centre for Tax Policy and Administration, explains the issues. Host: Rory Clarke Guest: Grace Perez-Navarro Producer: Samia Basille To learn more about the OECD's initiatives on tax, visit: https://www.oecd.org/tax Get the latest OECD content delivered directly to your inbox! Subscribe to our newsletters: www.oecd.org/newsletters Follow us on social media: www.oecd.org/social-media

The G20/OECD Inclusive Framework on Base Erosion and Profit Shifting (the Inclusive Framework) released two detailed “blueprints” in relation to its ongoing work to address the tax challenges arising from the digitalization of the economy.

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Chairman Dave Camp (Senior Policy Advisor in PwC's Washington National Tax Services practice and former Chairman of the House Committee on Ways and Means) discuss the past, present, and future of tax policy. Doug and Chairman Camp discuss: Chairman Camp's proposals for a global minimum tax during his tenure in Congress and how his proposals compare to the OECD's Base Erosion and Profit Shifting (BEPS) project; Vice President Biden's tax proposals, including amending the corporate tax rate, imposing a tax on book income, eliminating tax preferences for certain industries, and doubling the tax rate for global intangible low-taxed income (GILTI); the roles that the Senate, the US economy, and the global economy play in potential tax reform; President Trump's tax proposals; the evolution of the 'party platform,' political parties, and political factions; similarities and differences between the American political system and parliamentary systems; and the impact and utility of social media in the political sphere. [NOTE: This episode was recorded prior to the release of the "The Biden-Harris Plan to Fight for Workers" fact sheet released on September 9 by the Biden-Harris campaign.]

A review of the week's major US international tax-related news. In this edition: IRS issues final Base Erosion and Anti-abuse Tax (BEAT) regulations – IRS Notice 2020-69 announces plans to issue regulations on application of Sections 951 and 951A to certain S corporations with accumulated E&P – IRS requests comments on collection of information for competent authority requests – OMB OIRA receives final and proposed FTC regulations for review.

* Use coupon code PODCAST25 for 25% off this webcast * Webcast URL: https://www.theknowledgegroup.org/webcasts/trends-and-developments-on-gilti-fdii-and-beps/ Join us for this Knowledge Group Trends and Developments on GILTI FDII and BEPS CLE Webinar. The international tax landscape is expected to dramatically change before 2019 ends as developing countries consider a new global tax system and as the Tax Cuts and Jobs Act (TCJA) moves closer towards full implementation. Recent developments that should give us a glimpse of the future include the final set of global intangible low-taxed income (GILTI) regulations, the newly proposed foreign-derived intangible income (FDII) rules, and the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) program which aims to address “the tax challenges arising from the digitalisation of the economy.” U.S. companies should revisit their tax strategies to cope with the looming changes. Join a panel of key thought leaders and practitioners assembled by The Knowledge Group as they delve into an in-depth analysis of the current and emerging trends and developments surrounding GILTI, FDII, and BEPS enforcement. Speakers will also offer helpful insights on how to develop and implement effective strategies to mitigate risks and pitfalls and ensure compliance in this evolving regulatory climate. For any more information please click on the webcast URL at the top of this description.

Guest Jonathan Horn returns to “Simply Tax” to discuss the recent Association of International Certified Professional Accountants (AICPA) policy paper on the taxation of the digitalized economy, explain why current international concepts don’t fit well with digital transactions and break down the unique challenges countries face with the taxation of digital transactions in a cross-border context. TIME STAMPS OF WHAT’S COVERED Challenges with the taxation of the digitalized economy @2:04 Permanent establishment @7:23 The Organisation for Economic Co-operation and Development (OECD) commitment @8:40 Why the AICPA issued a policy paper @14:55 Fixing the problem today and five years from now @17:44 Three possible pathways under consideration: User value creation @22:27 Digital permanent establishment @25:24 Marketing intangibles @31:46 What’s ahead for the taxation of digital transactions @35:40 Where to find out more @40:33 Blockchain and the digital economy @45:26 BIO FOR GUESTS Jonathan Horn is a senior manager on the AICPA’s Tax Policy & Advocacy Team, based in Washington, D.C. He is responsible for developing and submitting comments to Congress, Treasury and the IRS and developing alerts for members. Prior to joining the AICPA, he was a sole practitioner for more than 20 years, providing tax services to clients of all sizes around the globe. In 2015, Jonathan received the AICPA Tax Division Distinguished Service Award for his extraordinary contributions to the work of the AICPA Tax Division. Connect with Jonathan on LinkedIn Follow Jonathan on Twitter ADDITIONAL RESOURCES AICPA resources Taxation of the digitalized economy: A policy paper designed to educate, enlighten and stimulate discussion (October 18, 2019) Interview with Chip Harter, Deputy Assistant Secretary (Internal Tax Affairs) at U.S. Department of the Treasury (September 18, 2018) Other resources OECD website Base Erosion and Profit Shifting Actions GET MORE “SIMPLY TAX” A complete archive of our episodes is available on our website and YouTube playlist. We’d love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram

Guest Jonathan Horn returns to “Simply Tax” to discuss the recent Association of International Certified Professional Accountants (AICPA) policy paper on the taxation of the digitalized economy, explain why current international concepts don't fit well with digital transactions and break down the unique challenges countries face with the taxation of digital transactions in a cross-border context. TIME STAMPS OF WHAT'S COVERED Challenges with the taxation of the digitalized economy @2:04 Permanent establishment @7:23 The Organisation for Economic Co-operation and Development (OECD) commitment @8:40 Why the AICPA issued a policy paper @14:55 Fixing the problem today and five years from now @17:44 Three possible pathways under consideration: User value creation @22:27 Digital permanent establishment @25:24 Marketing intangibles @31:46 What's ahead for the taxation of digital transactions @35:40 Where to find out more @40:33 Blockchain and the digital economy @45:26 BIO FOR GUESTS Jonathan Horn is a senior manager on the AICPA's Tax Policy & Advocacy Team, based in Washington, D.C. He is responsible for developing and submitting comments to Congress, Treasury and the IRS and developing alerts for members. Prior to joining the AICPA, he was a sole practitioner for more than 20 years, providing tax services to clients of all sizes around the globe. In 2015, Jonathan received the AICPA Tax Division Distinguished Service Award for his extraordinary contributions to the work of the AICPA Tax Division. Connect with Jonathan on LinkedIn Follow Jonathan on Twitter ADDITIONAL RESOURCES AICPA resources Taxation of the digitalized economy: A policy paper designed to educate, enlighten and stimulate discussion (October 18, 2019) Interview with Chip Harter, Deputy Assistant Secretary (Internal Tax Affairs) at U.S. Department of the Treasury (September 18, 2018) Other resources OECD website Base Erosion and Profit Shifting Actions GET MORE “SIMPLY TAX” A complete archive of our episodes is available on our website and YouTube playlist. We'd love to hear from you! Email feedback and questions to SimplyTax@bkd.com. Connect with Damien on social media! LinkedIn | Twitter | Instagram

Multinational base erosion and profit shifting harms Australia through lost tax revenue. Here is Simon Dorevitch of A & A Tax Legal Consulting with more.

Multinational base erosion and profit shifting harms Australia through lost tax revenue. Here is Simon Dorevitch of A & A Tax Legal Consulting with more.

Bloomberg Tax's John Bentil and Meg Hogan discuss an overview of the base erosion and anti-abuse tax (BEAT).

The new base erosion and anti-abuse tax (BEAT) generally imposes a 10% minimum tax (5% in 2018) on a taxpayer’s income determined without regard to tax deductions arising from base erosion payments (including the portion of a taxpayer’s NOL treated as related to base erosion payments) which generally cannot be reduced by credits other than, until 2025, the R&D credit and 80% of certain other credits. This Bottom Line videocast discusses: A brief overview of BEAT A simplified example of the BEAT calculation

The new base erosion and anti-abuse tax (BEAT) generally imposes a 10% minimum tax (5% in 2018) on a taxpayer’s income determined without regard to tax deductions arising from base erosion payments (including the portion of a taxpayer’s NOL treated as related to base erosion payments) which generally cannot be reduced by credits other than, until 2025, the R&D credit and 80% of certain other credits. This Bottom Line videocast discusses: A brief overview of BEAT A simplified example of the BEAT calculation

A review of the week's major US international tax-related news. In this edition: OECD conference focuses on Base Erosion and Profit Shifting (BEPS), House Ways and Means moves a bit on US tax reform, and PLR 201321007 on domestication of a foreign parent corporation holding a USRPHC.