2023

Reuven S. Avi-Yonah examines why countries have embraced unilateral digital services taxes and, in light of pillar 1’s grim outlook, how the United States can learn to live with them.

Chile’s Senate unanimously approved a tax treaty with the US, bringing the agreement one step closer to taking effect.

Enacted as part of the Inflation Reduction Act of 2022, the US Corporate Alternative Minimum Tax is in effect for all tax years beginning after December 31, 2022, but the IRS and taxpayers alike continue to learn more about the contours and pitfalls of the CAMT.

The European Union is considering extending the purview of its carbon border tax to a limited number of other sectors, according to a European Commission official.

Democrat and Republican House lawmakers are asking for an additional pause on newer, more stringent foreign tax credit rules, a move the IRS already hinted may be coming.

Lee A. Sheppard examines the impact of the pillar 2 income inclusion rule, qualified domestic minimum top-up tax, and undertaxed profits rule on the foreign tax credit for U.S. multinationals.

Mindy Herzfeld examines the latest developments in the OECD’s international tax work, including the two-pillar project.

In order to address potential gaps in existing information exchange, 48 countries have formally signed on to the OECD’s cryptoasset reporting framework.

Germany’s Parliament has approved a law transposing the EU’s global minimum tax directive into national law, in line with pillar 2 of the OECD’s two-pillar plan to modernize the international corporate tax system.

The Finnish government is asking for input on whether it should sign a multilateral convention implementing a reallocation of taxing rights as part of pillar 1 of an OECD-brokered, two-pillar global tax overhaul.

Nigeria will boost incentives for foreign investors in an attempt to address a decline in capital coming into the country as part of the government’s plans to revive the economy.

Forty-eight countries said Friday they are moving ahead with implementing a global crypto-asset reporting framework by 2027.

After years of delaying the applicability date of earlier regulations, the IRS has released long-awaited proposed regs on income and foreign currency gain or loss for qualified business units.

Chile’s lower house unanimously approved a tax treaty with the US on Wednesday, sending the bill to the Senate, where it could become law in the coming weeks, the Finance Ministry said.

Finland is requesting opinions from stakeholders on whether the country should sign onto a multilateral tax treaty that’s part of the OECD-led international tax pact.

The European Union reaffirmed its support for the international two-pillar tax deal and confirmed recent guidance on the global minimum tax aligns with the EU’s implementation of the rule, according to a statement issued by finance ministers.

The Barbados government will implement a domestic minimum top-up tax aligned with pillar 2 global minimum tax rules as part of a plan to overhaul its corporate tax system, according to Prime Minister Mia Mottley.

Multinational groups with presence in Brazil should analyze the tax profile of their Brazilian entities in view of the potential elimination of the long-standing interest on equity tax deduction.

Brazil’s senate approved a reform to simplify one of the world’s most byzantine tax codes.

An international agency monitoring tax transparency reported most of its member countries are complying with tax information exchange standards, but the availability of certain information can be improved.

An IRS official has confirmed that the agency still plans to release foreign tax credit guidance on pillar 2 by year-end and expects to extend temporary relief from final FTC rules at the same time.

A combination of government policies is finally succeeding in reversing a long decline in solar manufacturing in the United States.

The IRS plans to go ahead with guidance on how foreign tax credit regulations interact with the new global minimum tax even though it’s still considering whether and how those regulations might be modified, an IRS official said Monday.

Implementation of global minimum tax rules is happening, and there’s nothing the United States can do to stop it, members of the European Parliament subcommittee on tax matters told U.S. lawmakers.

Italy has introduced an innovative dispute prevention and resolution provision based on the principle of reciprocity as part of its pillar 2 implementation strategy, according to a finance ministry official.

A White House economist has responded to ExxonMobil’s support for a carbon tax by casting serious doubt on the possibility of achieving a global harmonized carbon market without any climate policy deviations.

Jamaica plans on establishing a qualified domestic minimum top-up tax as part of its implementation of the pending global minimum tax, a Jamaican official said Tuesday.

The US and Canada are headed toward a “big fight” over Canada’s plans to enact a digital services tax unless a solution is found, US Ambassador David Cohen said Tuesday.

Wally Adeyemo, the deputy Treasury secretary, said the United States was continuing to look for ways to improve coordination with Europe on climate and energy security initiatives.

The United States considers the treatment of the nonrefundable research credit by the pillar 2 global minimum tax regime an important priority as countries begin to implement the legislation, a Treasury official said.

Argentina will be ready to present a proposal for a withholding tax mechanism on digital service providers if progress isn’t made soon on the signing of a multilateral convention implementing pillar 1, an Argentine official said.

Oliver Treidler explains the structure of the OECD’s amount B and reviews its discussion draft comments and suggestions submitted by many industry participants.

A draft treaty that would implement a key part of the OECD’s global tax agreement represents “significant progress,” but work remains to be done, a Treasury Department official said Monday.

The pricing of intangibles in related-party transactions will cause unsolvable disputes unless the OECD provides revised guidance, according to panelists at the annual Congress of the International Fiscal Association in Cancun, Mexico.

If Bulgaria doesn’t join other EU member states in including a substance-based carveout in its proposed domestic minimum top-up tax, it will damage its ability to attract foreign investment, a trade group warned.

A senior Treasury official is offering greater detail on what public input the department is seeking in response to the amount A multilateral convention under pillar 1, including comments on what the draft document got wrong.

During a debate at the EU’s annual tax symposium about the advantages of the OECD's global tax reform plan versus a U.N. tax convention, the OECD said developing countries helped to shape its tax pillars.

Global minimum tax rules and a common EU corporate tax system will likely overload companies’ capacity for compliance because the interplay between the regimes could be overly complex, a business representative warned.

The Netherlands should consider other options in case countries can’t reach agreement soon on the amount A multilateral treaty under pillar 1 of the two-pillar global tax reform plan, a Dutch tax official told parliament.

The Court of Federal Claims has allowed a U.S. couple residing in France to use the France-U.S. tax treaty to claim a foreign tax credit against their net investment income tax liability.

Businesses large and small are being hit by a change in tax rules on R&D expenses. Some are struggling to stay afloat.

The inclusive framework on base erosion and profit shifting is considering issuing pillar 2 guidance on the treatment of deferred tax assets in jurisdictions with federal and subnational taxes, an OECD official said.

An initial projected revenue increase under pillar 2 global minimum tax rules has diminished because of negotiated concessions like a substance-based carveout and generous treatment of tax credits, according to a sweeping EU study.

Nongovernmental organizations have expressed disappointment regarding the EU’s hesitancy about joining a legally binding U.N. tax convention, but EU officials said they believe it would duplicate and could undermine the OECD’s work.

Disagreements between the global north and south and debates over whether the U.N. or OECD should lead on tax matters could cause a breakdown in multilateral tax cooperation, a Colombian government adviser warned.

Suranjali Tandon and Chetan Rao explain the potential importance of amount B for developing countries and suggest ways that amount B can be improved to address specific developing country needs.

Amplifying its efforts to go after tax dodgers, the IRS Friday announced new efforts to target foreign corporations and the largest corporate taxpayers.

In their compromise report on the role of tax policy in times of crisis, members of the European Parliament have called for a broader excess profits tax net and inflation-adjusted personal income tax brackets.