July 2017  
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Issue No.6a - 2017 of the Bulletin for International Taxation is now available online.
 
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Number 6a - 2017 contains the following:

SPECIAL ISSUE ARTICLES AUTHORED BY IBFD AND TAX ANALYSTS


United States/International

US Tax Reform and Its Global Impact – Editorial

Aleksandra Bal and Mike Hammer

US Tax Reform and Its Global Impact – Editorial

In this editorial, the authors comment on the proposed US tax reform measures and provide background to this Special Issue of the Bulletin for International Taxation.

United States

Flickers of Hope Remain for US Tax Reform – Editorial

Jeremy Scott

In this editorial, the author considers the likelihood and scope of US tax reform.

United States/European Union

The Trump Tax Reform Plan: Implications for Europe

Reuven S. Avi-Yonah and Gianluca Mazzoni

The Republican majority in Congress and President Trump have advanced several proposals for reforming the US tax system. The details vary, and that variation has significant implications for European foreign direct investment (FDI) into the United States and for US FDI into the European Union. Under the House Blueprint, the United States will become (from an EU tax perspective) the world’s largest corporate tax haven, leading to an increase in EU direct investment into the United States. Under the Trump Plan, there will be additional incentives for US multinationals to shift profits to Europe. This article discusses similarities and differences between the House Blueprint and Trump Plan, and their implications for FDI.

United States/European Union

The Missing Piece of the US Tax Reform: Would VAT Make America Great Again?

Aleksandra Bal

Taking into account the rapid expansion of VAT, its reputation for revenue generation and President Trump’s concerns about fair trade policy, the question arises why the United States does not have and does not intend to implement a VAT. In this article, the author summarizes and comments on President Trump’s and House Republicans’ positions on VAT and border tax.

United States

The Destination-Based Cash Flow Tax Is a VAT?

Peter A. Barnes and H. David Rosenbloom

In this article, the authors explain why it is misleading to analogize the border feature in the House Republicans’ destination-based cash flow tax with the border adjustment found in most VATs.

Germany/United States

US Tax Reform: The Implications in a Germany-US Context

Sven-Eric Bärsch, Marcel Olbert and Christoph Spengel

This article considers the implications of the US administration’s proposed tax reform, including a reduction in tax rates and a move to a territorial system of taxation, with regard to investment in the United States and for the financing, operating and tax planning policies of German and US multinational enterprises.

United States/International

Trump’s Corporate Income Tax Rate Reduction: A CFC Trap for Foreign-Controlled US Subsidiaries

Victor T. Chew

President Trump’s proposed tax reform includes a reduction of the corporate income tax rate from 35% to 15%. From the non-US point of view, this article warns that this will trigger the operation of controlled foreign company regimes.

United States/European Union

The U.S. Border Tax and Its Implications for the EU

Joachim Englisch and Johannes Becker

In this article, the authors examine how U.S. tax reform plans, including a destination-based cash flow tax with border tax adjustment, could affect EU member states.

Netherlands/United States

US Tax Reform: Possible Impact on the Netherlands

Paul de Haan, Premkumar Baldewsing and René Offermanns

In this article, the authors discuss the possible impact on the Netherlands of the recently proposed tax reform in the United States.

United States

Revisiting Camp's Repatriation

Mindy Herzfeld

In this article, the author discusses a mandatory deemed repatriation provision that was proposed in the House Republicans' Blueprint and the Tax Reform Act of 2014 (Camp's Bill).

China (People’s Rep.)/United States/OECD

Trump’s Tax Reform Plan: A Chinese Perspective

Na Li

In this article, the author discusses two directions that the Chinese government could take in response to President Trump’s tax reform plan: (1) engage in tax competition with the United States; or (2) ignore Trump’s proposal and adhere to China’s own plans for tax reform.

Singapore/United States
Putting Territoriality in Its Place: Singapore's Perspective on Tax Competitiveness

Stephen Phua

Even with the relative lack of concrete details, any possibility of tax reform in the United States generally attracts significant amounts of attention from all around the world. This is especially true now, with the looming of what appears to be the biggest tax reform since 1986. Of the many proposals within this reform, this article will focus on the proposed shift to a territorial tax system and reduction in corporate tax rates. It will demonstrate that the reform is overdue in the light of international norms and trends. In underscoring the imperatives of the proposed US tax reform, this article will evaluate and analyse the impact of these trends and the relevant experiences of some other countries. In particular, it will discuss in greater detail a similar tax reform initiative of Singapore in 1986 as well as the issue of a Singapore-United States double tax agreement.

United States/European Union

The European Union and the United States: The Good Old Tax “Frenemies” in the Shadows of Reforms

Pasquale Pistone and Yariv Brauner

In this article, the authors discuss the long-standing cooperation between the United States and the leading Member States of the European Union and comment on recent tax developments in these countries.

United States/European Union

Practical Analysis of the Potential Effects of US Border Adjustments on Goods Supply Chains from the EU Perspective

Miguel Adolfo Rodriguez Cuadros

In this article, the author considers the practical implications of the implementation of border adjustments in the supply chain by the United States as proposed in the Republican Party’s A Better Way - Our Vision for a Confident America of June 2016 from the perspective of the European Union.

United States

US Tax Reform: Is There Likely to Be “Real” Simplification?

Adrian J. Sawyer

President Donald Trump’s proposed reforms, which are long on rhetoric and short on detail, would affect almost every individual and corporate in the United States, leading to lower income tax, especially for the wealthy and larger businesses, and significant spill-over effects beyond the United States. This article focuses on the extent to which the proposed changes may reduce complexity and facilitate simplification.

United States

What Will Be in Tax Reform?

Lee A. Sheppard

In this article, the author reports on the recent demise of the border adjustment tax and briefly describes the remaining elements of the proposed US tax reform.

Brazil/United States

US Tax Reform: The Potential Tax Implications for Brazilian Taxpayers

Ramon Tomazela Santos

In this article, the author analyses the main corporate tax reform proposals under discussion in the United States and their potential implications for Brazilian taxpayers.

United States/Latin America

The “Biggest Tax Cut” from the Latin American Perspective

Carolina Vaca Bohorquez

In this article, the author examines the recently proposed US tax reform, which is intended to be the “biggest tax cut” in the history of the United States, from a Latin American perspective.

Belgium/United States/European Union/OECD

A Small Fish in a Big Pond: The International Tax Options of Belgium

Frans Vanistendael

In this article, the author discusses the international tax options of Belgium in light of the one-page tax reform proposal released on 26 April 2017 by US President Donald Trump.

India/United States

US Tax Reform: The International Tax Implications for India – The “India-US Business Corridor”

Sagar Wagh

This article considers how investors in India and the United States will be affected by the US tax reform and whether the India-United States Income Tax Treaty (1989) will require revision. The emphasis is on the tax and economic implications of the US tax reform for the India-US business corridor.

United States/International

The Impact of the Net Investment Income Tax on Non-American Investors

James G.S. Yang and Jeffrey S. Warren

President Donald Trump announced his intention to repeal the Net Investment Income Tax (NIIT). In this article, the authors examine the functioning of the NIIT and its impact on non-resident alien investors.

China (People's Rep.)/United States

The Debate Over U.S. Corporate Tax Reform: How Should China Respond?

Zhiyong An

In this article, the author analyzes how tax reform proposals in the U.S. may affect China and makes suggestions for how China should respond, sketching a blueprint for a Chinese tax system that includes reform to the corporate tax, VAT, and individual income tax systems.

United States

Planning for Border Adjustments: A Practical Analysis

David P. Hariton

In this article, the author explains why he thinks the border adjustments proposed by the House Republicans’ blueprint will be much more complicated to implement than many people realize.

United States

The White Working Class and Post-2016 Tax Policy

Mindy Herzfeld

In this article, the author discusses the recent shifts in the US economy and demographic structure, and their impact on the tax policy debate.

United States/International

The Border Adjustment: What Companies Need to Know

Timothy Reichert and Perry Urken

In this article, the authors analyze how the adoption of a border adjustment by the United States would affect corporations. They demonstrate that this would cause both double taxation of import flows and non-taxation of export flows, contrary to the principles of international tax treaties and the recent OECD base erosion and profit-shifting initiative.

United States

Aging Labor Force Lowers U.S. Economic Growth

Martin A. Sullivan

In this economic analysis, the author looks at labor force participation rates over the years and how economic growth might be affected by an aging labor force.

United States

Economic Analysis: Basic Cash Flow Taxation of Financial Institutions

Martin A. Sullivan

In this article, the author discusses the consumption tax treatment of financial transactions from an economic perspective.

United States

Unlike VAT, Cash Flow Tax Helps Exports, Hits Imports

Martin A. Sullivan

In this article, the author examines the functioning of the destination-based cash flow tax. The article builds upon and extends the analysis of a recent paper by Alan Auerbach and Douglas Holtz-Eakin (2016) entitled The Role of Border Adjustments in International Taxation.

United States

The Brady-Ryan Plan: Potential and Pitfalls

Alan D. Viard

In this article, the author argues that the Brady-Ryan tax plan has significant pro-growth potential because it moves toward consumption taxation, and he identifies some features of the plan that should be changed.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION