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Are Opportunity Zones Working as Intended?

New Research Shows Small Firms Value Simplicity More Than Tax Relief

The Challenges of Consensus in the Digital Economy on the International Tax Treaty System

How Controlled Foreign Corporation Rules Look Around the World: United States of America

The United States was the first country to enact CFC rules, and it is probably the country with the most complex set of rules that will be presented in this blog series. The rules determine control using a combined ownership test: one for the corporation and the other at the shareholder level. The assessable income under the rules is generally passive income but the amount of foreign income subject to U.S. tax has expanded with the adoption of GILTI.

Millionaires’ Tax Take Two: Massachusetts legislature moves forward Millionaires’ Tax

Talking Tax Reform: Excise Taxes in the 21st Century

Maine Hotels and Campgrounds Would Have Felt LOST If Bill Became Law

How Patent Boxes Impact Business Decisions

As with every change in tax policy, there are trade-offs. The Modified Nexus Approach adds an additional layer of complexity to the already complex issue of taxing IP income. Linking tax breaks for IP income to its associated R&D activity has changed the game and will likely result in some businesses restructuring and relocating their IP assets and R&D activity. Effective tax rates on IP income will likely play an important role in determining optimal locations, giving measures such as R&D credits more importance. Whether this new approach to IP taxation will impact profit shifting and which countries will be the winners and losers is yet to be seen.

Patent Box Regimes in Europe, 2019

Distilled Spirits Taxes by State, 2019