Magnifying Your Voice with USCIB:
- USCIB’s Tax Committee is the most respected U.S. business association on international tax issues. USCIB is the only U.S. business association formally affiliated with the world’s three largest business organizations where we work with business leaders across the globe to extend our reach to influence policymakers in international markets that are important to American business.
Trends and Challenges Facing U.S. Business:
- Multiple sets of inconsistent rules that drive up costs and result in double taxation
- The mounting political pressure to move towards changing the taxation of the digitalized economy
- Efforts to unfairly increase the tax burden on companies
USCIB’s Response:
- Build consensus with like-minded industry peers and participate in off-the-record briefings with policymakers both home and abroad
- Engage with the OECD on the development of international taxation principles
- Proactively shape the development of the OECD’s guidance on the taxation of the digitalized economy by demonstrating to policymakers that unilateral action can result in double taxation, decreased trade, and reduced global growth
- Actively monitor and contribute to the work of the UN Committee of Tax Experts to ensure its alignment with the work of the OECD Tax Committee and inform policymakers of their actions’ impact on investment
- Support enactment of foreign tax simplification provisions in the IRC that would significantly reduce the burden of complexity for U.S. companies and enhance their international competitiveness
- Host an annual conference in Washington, DC that provides a unique opportunity for the U.S. business community to interact with key representatives from the OECD Centre for Tax Policy and Administration (“CTPA”).
Recent Accomplishments:
- Submitted a USCIB consultation letter to the OECD on Pillar One – Tax Certainty for Issues Related to Amount A
- Submitted a USCIB MDSH design letter to the Treasury
- Submitted a USCIB consultation letter to the OECD on the Extractives Exclusion rules.
- Submitted a USCIB letter for the European Commission VAT in the Digital Age consultation.
- Submitted a USCIB letter on Amount B – M&D functions lists to U.S. Treasury.
- Submitted a USCIB letter on the OECD Public Consultation Document “Pillar One – Amount A: Draft Model Rules for Domestic Legislation on Scope”.
- Submitted a second USCIB letter expressing significant concerns with the final foreign tax credit regulations (T.D. 9959, 87 Fed. Reg. 276).
- Submitted a USCIB letter on the OECD Public Consultation Document “Pillar One – Amount A: Draft Model Rules for Tax Base Determinations”.
More Recent Accomplishments
- Signed onto a trade association letter to Congressional leaders regarding the deduction of business’ R&D expenses.
- Submitted a USCIB letter to Treasury expressing significant concerns with the final foreign tax credit regulations (T.D. 9959, 87 Fed. Reg. 276).
- Submitted a USCIB letter on Extra-territorial Taxation of Income from the Licensing and Sale of Intellectual Property Registered in Germany (§ 49 EStG).
- Submitted a USCIB letter to Treasury on the design of the proposed marketing and distribution safe harbor (“MDSH”).
- Submitted USCIB comments on the OECD Public Consultation Document “Pillar One – Amount A: Draft Model Rules for Nexus and Revenue Sourcing.
- Submitted USCIB comments on the draft agenda for 23rd Session of the Committee of Experts on International Cooperation in Tax Matters.
- Signed onto a trade association letter in opposition to H.R. 3007, the “Disclosure of Tax Havens and Offshoring Act.
- Submitted USCIB comments on the Inception Impact Assessment for the VAT rules for Financial and Insurance Services.
- Submitted USCIB comments on the discussion draft on the inclusion of software payments in the definition of royalties.
- Submitted USCIB comments on the Inception Impact Assessment on the EU Digital Levy.
- Submitted USCIB comments related to 2020 Proposed Guidance Related to the Foreign Tax Credit; Clarification of Foreign Derived Intangible Income (IRS REG-101657-20).
- Submitted USCIB comments on the OECD Public Consultation Document on the Reports on the Pillar One and Pillar Two Blueprints.
- Submitted USCIB comments related to 2020 Proposed Regulations under Sections 958(b) and 954(c)(6) (REG-110059-20).
- Submitted USCIB comments related to 2020 Proposed Regulations under Section 163(j) (REG-101911-
18). - Submitted USCIB comments to the OECD regarding their upcoming guidance on the application of the OECD Transfer Pricing Guidelines in light of the COVID-19 crisis.
- Submitted USCIB comments to the UN on their discussion draft on the inclusion of software in the definition of royalties.
- Submitted USCIB comments to on the proposed regulations (IRS REG-127732-19) under section 954(b)(4) regarding income subject to a high rate of foreign tax.
- Submitted USCIB comments to the UN on their draft of Article 12B covering the taxation of automated digital services.
- Submitted USCIB comments to the UN on the proposals concerning modifications to Article 13 and its commentary, including the proposals on Offshore Indirect Transfers (OIT).
- Submitted USCIB comments on the 301 investigation of the Digital Services Taxes.
- Submitted USCIB comments to the OECD’s Forum on Tax Administration (FTA) on how to support tax administrations during the COVID-19 pandemic.
- Submitted USCIB comments on the UN’s draft paper on software royalties.
- Submitted USCIB comments on the proposed regulations (IRS REG-106013-19) regarding guidance related to certain hybrid arrangements and conduit financing arrangements.
- Submitted USCIB comments on the Inclusive Framework’s Public Consultation Document on the Model Rules for Reporting by Platform Operators with respect to Sellers in the Sharing and Gig Economy.
- Submitted a letter to Secretary Mnuchin that highlights high-level international tax policy concerns that have arisen as a result of the global pandemic.
- Submitted USCIB comments on the OECD’s Public Consultation Document: Review of Country-by-Country Reporting (BEPS Action 13).
- Submitted USCIB comments on the IRS proposed regulations regarding guidance related to the foreign tax credit and related provisions (REG-105495-19).
- Submitted USCIB comments on the IRS proposed regulations regarding guidance related to the Base Erosion and Anti-Abuse Tax (“BEAT”) under section 59A (REG-112607-19).
- Submitted USCIB comments to USTR on the Section 301 Investigation of France’s Digital Services Tax.
- Submitted USCIB comments on the OECD Public Consultation Document on Global Anti-Base Erosion Proposal (“GloBE”) Pillar Two.
- Submitted USCIB comments to the UN Committee of Tax Experts on the issue of the taxation of software royalties.
- Submitted USCIB comments on the IRS proposed regulations regarding the classification of cloud transactions and transactions involving digital content.
- Submitted USCIB comments on the OECD Secretariat’s Proposal for a “Unified Approach” under Pillar One.
- Submitted comments on the Platform for Collaboration on Tax’s Toolkit on Transfer Pricing Documentation.
- Submitted a letter to Secretary Mnuchin urging Treasury to remain committed to the OECD process to reform the international tax rules as part of the effort to address the tax challenges of thedigitalizing economy.
- Submitted comments to the IRS on the proposed regulations regarding guidance related to rules for determining stock ownership and Global Intangible Low-Taxed Income or “GILTI” under section 951A (IRS REG-101828-19).
- Submitted comments to the IRS on the proposed and temporary regulations regarding guidance related to rules regarding the limitation on deduction for dividends received from certain foreign corporations and amounts eligible for section 954 look-through exception (IRS REG-106282-18)
- Submitted comments to USTR on the Section 301 Investigation of France’s Digital Services Tax.
- Submitted a USCIB comment letter on New Zealand’s options for taxing the digital economy
- Submitted a USCIB comment letter on the update of the UN Practical Manual on Transfer Pricing for Developing Countries.
- Submitted USCIB comments on the proposed regulations regarding the deduction for foreign-derived intangible income (“FDII”) and global intangible low-taxed income (GILTI”) (IRS REG-104464-18).
- Submitted a comment letter on the OECD’s Public Consultation Document on Addressing the Tax Challenges of the Digitalisation of the Economy.
- Submitted a comment letter on the UK Treasury’s consultation document concerning digital services.
- Submitted a comment letter on the proposed regulations regarding guidance related to rules regarding certain hybrid arrangements under sections 245A(e) and 267A (REG-104352-18)
- Submitted a comment letter on the proposed regulations regarding guidance related to the limitation on deduction for business interest expense under section 163(j) (REG-106089-18)
- Submitted a comment letter on the proposed regulations regarding guidance related to the Base Erosion and Anti-Abuse Tax (“BEAT”) under section 59A (REG-104259-18).
- Submitted a comment letter on the proposed regulations regarding guidance related to the foreign tax credit.
- Submitted a comment letter on the proposed regulations regarding guidance related to Global Intangible Low-Taxed Income or “GILTI” under section 951A (REG-104390-18).
- Submitted a comment letter on the proposed regulations regarding the transition tax under Section 965 (REG-104226-18).
- Submitted a comment letter on the Platform for Collaboration on Tax’s revised toolkit on Offshore Indirect Transfers.
- Submitted a comment letter on the OECD Discussion Draft on BEPS Actions 8 -10 – Financial Transactions (“Discussion Draft”).
- Submitted a letter providing input regarding the direction of the UN’s subcommittee on Transfer Pricing for its work during the current term of the committee.
- Submitted a comment letter to Senators Portman and Cardin on their proposed “Protecting Taxpayers Act”.
- Submitted a comment letter to the European Commission in response to the recent issuance of two digital directives.
- Submitted a comment letter on HM Treasury’s position paper on Royalties Withholding Tax.
- Submitted a comment letter on HM Treasury’s position paper on corporate tax and the digital economy.
- Submitted a comment letter to the Treasury concerning the implementation of the new section 965.
- Submitted a comment letter on the Platform for Collaboration on Tax’s draft toolkit on the taxation of offshore indirect transfers of assets.
- Submitted a comment letter on the OECD’s request for input on work regarding the tax challenges of the digitalized economy.
- Submitted a comment letter on the OECD Discussion Draft on BEPS Action 10 – Revised Guidance on Profit Splits.
- Submitted a comment letter on the OECD Discussion Draft on BEPS Action 7 – Additional Guidance on the Attribution of Profits to Permanent Establishments.
- Submitted a comment letter on the proposed changes to OECD Model Income Tax Treaty and Commentary.
- Submitted a comment letter on a note by the UN Secretariat on certain procedural issues relating to the functioning of the Committee of Experts on International Cooperation in Tax Matters.
- Submitted a comment letter on the Platform for Collaboration on Tax’s Discussion Draft: A Toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analysis.
- Submitted a comment letter to the UN on a draft report from the Subcommittee on Royalties (the Subcommittee) concerning the taxation of royalties.
- Submitted a comment letter on the OECD’s Discussion Draft on BEPS Action 2 – Branch Mismatch Structures.
- Submitted a comment letter on the OECD’s Discussion Draft on BEPS Action 4 – Approaches to Address BEPS Involving Interest in the Banking and Insurance Sectors.
- Submitted a comment letter on the OECD’s Discussion Draft on BEPS Action 7 – Additional Guidance on the Attribution of Profits to Permanent Establishments.
- Submitted a comment letter on the OECD’s Discussion Draft on BEPS Actions 8-10 – Revised Guidance on Profits Splits.
- Submitted a comment letter on the OECD’s Discussion Draft on BEPS Action 4 – On Elements of the Design and Operation of the Group Ratio Rule.
- Submitted a USCIB response to the OECD’s request for comments on specific technical issues on implementation and on issues related to the development of the MAP arbitration provision, described in the Public Discussion Draft on Development of a Multilateral Instrument (“MLI”) to Implement the Tax Treaty related BEPS Measures (the “Discussion Draft”).
- Submitted a USCIB Response to the OECD’s Discussion Draft on Treaty Entitlement of Non-CIV Funds.
- Submitted a letter on the IRS’s proposed regulations on Country-by-Country Reporting.
- Submitted identical letters to the U.S. Treasury and the OECD expressing support for mandatory binding arbitration.
- Submitted a letter on the proposed changes to the U.S. Model Income Tax Treaty to the U.S. Treasury.
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Action 8: Hard-to-Value Intangibles.
- Submitted a USCIB Response to the OECD’s Revised Discussion Draft on BEPS Action 6: Preventing Treaty Abuse.
- Submitted a USCIB Response to the OECD’s Revised Discussion Draft on BEPS Action 7: Preventing the Artificial Avoidance of PE Status.
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Actions 8: Revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost Contribution Arrangements (CCAs).
- Submitted a USCIB Response to the OECD’s discussion draft on BEPS Action 3: Strengthening CFC Rules.
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Action 12: Mandatory Disclosure Rules.
- Submitted a USCIB Response to the OECD’s Discussion Draft on the B2C VAT Guidelines.
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Action 4: Interest Deductions and Other Financial Payments.
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Actions 8, 9, and 10: Discussion Draft on Revisions to Chapter 1 of the Transfer Pricing Guidelines (Including Risk, Recharacterisation and Special Measures).
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Action 10: Discussion Draft on the use of Profit Splits in the Context of Global Value Chains.
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Action 14: Make Dispute Resolution Mechanisms More Effective.
- Submitted a USCIB Response to the OECD’s Discussion Draft on Follow Up Work on BEPS Action 6: Preventing Treaty Abuse
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Action 7: OECD Discussion Draft on BEPS Action 7: Prevent the Artificial Avoidance of PE Status.
- Submitted a USCIB Response to the OECD’s Discussion Draft on BEPS Action 10: Proposed Modifications to Chapter VII of the Transfer Pricing Guidelines Relating to Low Value-Adding Intra-Group Services.
- Submitted a USCIB letter concerning the proposed modifications to the UN Commentary on Article 9.
- Submitted a USCIB Response to the OECD Discussion Draft on BEPS Action 11: Establish methodologies to collect and analyze data on BEPS and the actions to address it.
- Submitted a USCIB Response to the OECD Discussion Draft on BEPS Action 2: Neutralising the Effects of Hybrid Mismatch Arrangements (Domestic Rules).
- Submitted a USCIB Response to the OECD Discussion Draft on BEPS Action 2: Neutralise the Effects of Hybrid Mismatch Arrangements (Treaty Issues).
- Submitted a USCIB Response to the OECD’s Discussion Draft on the Tax Challenges of the Digital Economy.
- Submitted a USCIB letter on the OECD Paper on Transfer Pricing Comparability Data and Developing Countries.
- Submitted a USCIB letter on the OECD Discussion Draft on BEPS Action 6: Preventing the Granting of Treaty Benefits.
- Submitted a USCIB letter to the UN concerning the planned revisions to the UN Transfer Pricing Manual.
- Submitted USCIB Comments on the OECD Discussion Draft on Transfer Pricing Documentation and Country-by Country Reporting and the annexes.
- Submitted preliminary USCIB comments on several of the action items included in the OECD Action Plan on BEPS (Base Erosion and Profit Shifting) including comments on:
- Action Item 1 on digital economies (including an appendix)
- Action Item 2 on hybrid mismatches
- Action Item 4 on interest deductions
- Action Item 6 on prevention of treaty abuse & Action Item 7 on the prevention of the artificial avoidance of permanent establishment (PE) status
- Action Item 9 on risks and capital – as it relates to assuring that transfer pricing outcomes are in line with value creation.
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Timothy M. McDonald
Senior Vice President, Finance & Accounting, Global Taxes
The Procter & Gamble Company
Vice Chairs
Jocelyn Krabbenschmidt
International Tax Director
Apple Inc.
Will Morris
Deputy Global Tax Policy Leader
PwC
Tom Roesser
Senior Director, Tax Affairs
Microsoft Corporation
Vice Chairs (continued)
Daniel Smith
Director, International Tax Planning & Policy
Google Inc.
John A. Stowell
Senior Vice President – Tax
The Walt Disney Company
Louise Weingrod
Vice President, Global Taxation
Johnson & Johnson
Chad J. Withers
Global Tax Director
Caterpillar Inc.
USCIB Leadership
Rick Minor
Vice President and International Tax Counsel
202-682-7376 or rminor@uscib.org
Subcommittees
Transfer Pricing Subcommittee
VAT Subcommittee
Working Groups
EU Tax Working Group
