2023

Martin A. Sullivan explores financial data for more than 300 multinational companies to uncover trends in intellectual property transfers.

The United Kingdom will make full expensing for business capital investments permanent as part of a plan to invest £20 billion annually in businesses over the next decade, said Chancellor of the Exchequer Jeremy Hunt.

U.N. countries passed a resolution in committee to establish a framework convention for international tax cooperation, which would shift negotiations from the OECD to the U.N.

While EU countries generally reacted positively to the Spanish EU Council presidency’s proposal exempting comprehensive withholding tax relief systems from some Faster and Safer Relief of Excess Withholding Taxes provisions, several requested time to study the impact.

Colombia will seek to allow arbitration in tax disputes for the first time in a major step forward, although questions remain about the proposal’s efficacy, tax professionals say.

The UK government estimates it will net about £12.7 billion ($15.9 billion) from the global minimum tax over the next six years, according to figures published in its Autumn budget statement.

The U.K.’s top financial official, Jeremy Hunt, outlined measures to spur business investment and push more people into jobs.

Nana Ama Sarfo discusses Barbados's changing approach to pillar 2.

Despite opposition from business groups and the Biden administration, Canada has confirmed its intent to move ahead with its digital services tax just weeks before its planned effective date.

A draft resolution released by the UN calls for the development of a framework convention to make international tax cooperation more inclusive.

Income tax rates for companies have decreased on average over the past 23 years, according to a report on corporate tax statistics released by the OECD on Tuesday.

A note prepared by the EU Council's Spanish presidency suggests pursuing the European Commission's idea to maintain the tax consequences of its proposal to tackle the misuse of shell entities.

The cost of government support for electric vehicle battery manufacturing projects in Canada that includes U.S.-credit-matching subsidies to major automakers could exceed estimates by almost C $6 billion, a budget watchdog said.

Switzerland may postpone raising the minimum tax rate on multinationals to 15%, amid widespread delays in implementing a global deal on the issue.

The United States has joined 13 other countries from the Indo-Pacific region in agreeing to, among other measures, strengthen cooperation to combat cross-border tax evasion.

The Bermudian government is holding a third consultation on its proposed corporate tax regime — this time on draft legislation intended to align with the global anti-base-erosion rules under pillar 2.

U.N. members are expected to vote soon on a draft resolution that would lay the groundwork for a legally binding framework convention on international tax cooperation.

African countries at the United Nations called on richer nations to back their push to have the global body undertake negotiations toward reforming the world’s tax rules.

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.