Article from Forbes

1. European Tax Bureaucrats Are
Raising Taxes on U.S. Companies
and Undermining Tax Reform
PARIS, FRANCE - DECEMBER 07: Angel Gurria, Secretary General, Organization for Economic Co-
operation and Development (OECD), and Honorary President, Conference of Paris , Audrey Azoulay
Director General, United Nations Educational, Scientific and Cultural Organization (UNESCO), Pascal
Lamy President Emeritus, Jacques Delors Institute and Director General, World Trade Organization
(2005-2013), Jean Paul Agon Chairman and CEO of L Oreal attends the first edition of the Conference of
Paris of the International Economic Forum of the Americas, in Paris, on December 7, 2017 in Paris,
France. IEFA organizes annual summits bringing together heads of states, central bank governors,
ministers and global economic decision makers. This annual meeting focus on providing a better
understanding of the major challenges facing the global economy, with particular attention to relations
between Europe and other continents. (Photo by Christophe Morin/IP3/Getty Images)

2. In the wake of recent tax reform in the United States, one might
be tempted to think that a relatively quiet time of adjustment and
digestion is ahead when it comes to U.S. companies doing
business overseas. After all, a lot has changed--there's a "deemed
repatriation" tax on deferred foreign earnings, new "BEAT" and
"GILTI" tax rules to prevent tax base erosion and corporate
inversions, and of course a new 21 percent tax rate here at home.
But it seems that European tax bureaucrats at the OECD have not
gotten the message. Our old friends in Paris are still chasing the
old ghost of the big, bad American multinational with a tax
base insufficiently raided by European and other developed world
tax collectors.
The European Tax Grab
In April of this year, a French-led effort at the OECD will present
G-20 finance ministers with a plan to increase taxes on U.S. tech
companies doing business overseas. While you might think this
involves just a few dot coms, their definition of "tech" is broad
enough to include virtually any company doing business of any
kind online--which is every company, to state the obvious.
To gain leverage in these negotiations, the European Union in
March of this year will release the specifics of a tax increase plan
on U.S. companies. Options the E.U. might look at include a gross
receipts tax on sales, tax liability assertions that stretch the
definition of "nexus" to the breaking point, and even nebulous
concepts like how much value a company has extracted from
European consumers. Essentially, the E.U. wants to make up tax
rules as they go along, provided American companies lose.
If this sounds familiar, it's an echo of the "base erosion and profit
shifting" (BEPS) initiative of the Europeans from a few years ago.
Back then, they were concerned that the U.S. tax system's
worldwide character and indefinite deferral was creating tax

3. havens overseas. The U.S. Congress and President Trump fixed
that, however, in tax reform: the deferred income was taxed via a
deemed repatriation levy, we shifted to a territorial system, and
base erosion measures were taken that are universally believed to
be pretty airtight. Yet the Europeans still want the money, even if
the original BEPS rationale is now totally gone.
Source:
https://www.forbes.com/sites/ryanellis/2018/02/13/european-tax-bureaucrats-are-raising-taxes-on-u-s-
companies-and-undermining-tax-reform/#793599f92250