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   January 2019  
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Bulletin for International Taxation
 
This free e-mail service informs you about the contents of the forthcoming edition of Bulletin for International Taxation.

Issue No. 1 - 2019 of the Bulletin for International Taxation is now available online.

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Number 1 - 2019 contains the following:
ARTICLES

China (People’s Rep.)/Hong Kong/ India/Indonesia/Japan/Korea (Rep.)/ Singapore/OECD

The Potential Effect of Action 4 of the OECD Base Erosion and Profit Shifting Initiative Regarding Excessive Interest Deductions on Companies in Asia

Yue Dong and Balbir Kaur

This article examines the potential effect of Action 4 of the OECD Base Erosion and Profit Shifting Initiative regarding excessive interest deductions on multinational groups in seven Asian jurisdictions. The authors find that in almost all jurisdictions, companies in the manufacturing sector would be affected the most by the rules.

United States

US Supreme Court Overturns Quill (1992): Physical Presence Rule for State Sales Tax

Charles E. McLure, Jr.

In this article, the author considers the recent US Supreme Court (USSC) ruling in the case of Wayfair (2018) overturning the USSC case of Quill (1992), which provided a physical presence nexus rule, and implications of this decision for US state sales taxes.

United States

US Tax Cuts and Jobs Act: Part 1 – Global Intangible Low-Taxed Income (GILTI)

Carlos Perez Gautrin

This article is the first in a series on US taxation that explains the recent US tax reform enacted by the US Tax Cuts and Jobs Act by focusing on Global Intangible Low-Taxed Income (GILTI), Foreign Derived Intangible Income (FDII), and the Base Erosion and Anti-Avoidance Tax (BEAT).

World Trade Organization/International

The Overlap between Dispute Settlement Mechanisms in World Trade Organization Agreements and Tax Treaties

Alireza Salehifar

The rapid expansion of the membership of the World Trade Organization (WTO) poses a significant challenge to the operation of tax treaties. This article examines the possible clash of jurisdiction and the potential conflict between the dispute resolution mechanisms provided for by the WTO and in tax treaties.

Netherlands

The Deduction Limitation for Share Transaction Costs in the Netherlands

Shie Yee Au Yeung and Lex Bekkers

Share transactions often involve considerable costs for both the purchaser as well as the seller and not the least in respect of costs for legal support, such as those relating to lawyers, notaries and (tax) advisers. These costs are not always deductible from the taxable profits of Dutch companies.

Available online only

OECD/International

Conceptual Problems of Beneficial Ownership in Respect of Agents and Nominees

Saurabh Jain and John Prebble

The Conduit Companies Report and certain courts have considered that the presence of dominion automatically indicates that an interposed company is not a conduit. This article argues that they have been misled by the official commentary on articles 10, 11 and 12 of the OECD Model as it stood in 1977.

Available online only

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