February 2017  
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Bulletin for International Taxation
 
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Issue No. 2 - 2017 of the Bulletin for International Taxation is now available online.

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Number 2 - 2017 contains the following:
ARTICLES

United States/International

O Brave New World: The Looming Rethink of International Taxation in the United States

H. David Rosenbloom

In the Klaus Vogel Lecture of 23 September 2016, hosted by the Institute for Austrian and International Tax Law (WU), Vienna, David Rosenbloom provides his thoughts and observations on the, in his view necessary, reform of the international taxation system of the United States.

United States/International

Comments on Professor David Rosenbloom’s Lecture “O Brave New World: The Looming Rethink of International Taxation in the United States”

Gerhard Kraft

Prof. Dr Gerhard Kraft comments on Professor Rosenbloom’s Klaus Vogel Lecture of 23 September 2016, hosted by the Institute for Austrian and International Tax Law (WU), Vienna, the title of which was “O Brave New World: The Looming Rethink of International Taxation in the United States”.

Argentina/Chile/Colombia/Mexico/United States

A Comparative Analysis of the Indirect Foreign Tax Credit in Latin America and in the United States - Part II

Diana Calderón Manrique

Part II of this article continues the country-based comparison of indirect foreign tax credit systems started in Part I by considering Mexico and the United States. These systems are then compared in all five countries examined. The article next considers the relevant policy issues before ending with conclusions and recommendations.

China (People’s Rep.)

Is China Internationally Tax Competitive?

Chien-Hsun Chen

Foreign-invested enterprises (FIEs) minimize their tax burden through transfer pricing or the use of lower-tax jurisdictions. Tax incentives are generally not sufficient to attract major flows of investment. China is not a low-tax country, but rather a recipient of substantial foreign direct investment (FDI) inflows. The author examines whether this affects China’s international tax competitiveness.

International/OECD

Thoughts on the Potential Effects of the OECD/G20 BEPS Action Plan on Collective Investment Vehicles – Part II

Moritz Scherleitner

In Part II of this article, the author continues his examination of the potential implications of the OECD/G20 Base Erosion and Profit Shifting initiative for collective investment vehicles.

Hong Kong/Singapore/International/OECD

The Territoriality Principle in the World of the OECD/G20 Base Erosion and Profit Shifting Initiative: The Cases of Hong Kong and Singapore

Wei Hwa See

In Part II of this article, the author examines the effect of the territoriality principle on tax treaties concluded by Singapore and Hong Kong. This is followed by an analysis of the interaction between the territoriality principle and the OECD/G20 Base Erosion and Profit Shifting initiative.

United States

Trump’s Take: A Tale of Two Tax Plans, Countless Promises and the Precarious Path to Enactment

Mike Hammer

In this article, the author provides a brief outline and analysis of Trump’s tax plan, draws comparisons with the tax plan proposed by House Republicans, examines to what extent the campaign promises of recent US presidential candidates have been kept and describes, in general, the complex process of enacting US tax legislation.

Available online only

China (People’s Rep.)/OECD

Status of the Implementation of the OECD/G20 BEPS Initiative in China and Future Developments

Na Li

The author, in this article, describes the status of the OECD/G20 Base Erosion and Profit Shifting initiative in China as at the end of 2016 and attempts to predict the further actions that China may take to continue the implementation of the initiative in the future.

Available online only

Argentina/Panama/OECD/WTO

World Trade Organization FInding on Anti-Avoidance Measures To Counter Foreign Preferential Tax Regimes versus the Free Flow of Capital and Investment

Guzmán Ramírez

This article considers the tax implications of the dispute brought before the World Trade Organization by Panama in relation to measures implemented by Argentina in response to the OECD/G20 Base Erosion and Profit Shifting initiative.

Available online only
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