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2023

EU Council Announces Agreement on Information Exchange Directive

The EU Council announced that it has reached a final agreement on the ninth directive on administrative cooperation (DAC9) that will implement the global minimum information exchange standard under the OECD’s two-pillar tax reform plan, noting that member states are required to enforce DAC9 by December 31.

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European Commission Refuses to Give Up on DEBRA

The European Commission is urging member states to drop their opposition to the Debt-Equity Bias Reduction Allowance directive without suggesting any adjustments to the proposal.

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Manufacturing a New Domestic Incentive

 Michael DiFronzo, Nick Zemil, and Yulia Markova explore the path to a domestic production benefit and the potential mechanics of a manufacturing incentive.

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EU Commission Reports on 2023 Tax Trends

The EU Commission has announced the availability of tax trend data from 2023, noting that EU member states collected €6.7 billion in taxes — a 4.7 percent rise from 2022 — with increases in labor taxes and capital taxes of 5.9 percent and 4.5 percent, respectively.

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Big Pharma Profits Stay Outside the United States

Martin A. Sullivan examines recent Form 10-K data from big pharmaceutical companies indicating that there is more worldwide, before-tax profit shifting outside the United States since passage of the Tax Cuts and Jobs Act.

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NFTC Comments on Transfer Pricing Approach Consultation

The National Foreign Trade Council in a March 7 letter responded to the IRS’s public consultation regarding Notice 2025-4, which outlines the IRS and Treasury’s plan to propose regulations that are compliant with the OECD’s simplified amount B standard, urging Treasury and the IRS to expand the transfer pricing approach to include more industries and services and provide necessary guidance.

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USCIB Calls for U.S. Leadership on Widespread Amount B Adoption

The United States must keep pushing for broader implementation of the amount B simplified and streamlined transfer pricing approach to avoid complexity and current controversy levels, the U.S. Council for International Business said.

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Tax Considerations for the Potential U.S. Annexation of Greenland

Libin Zhang considers the tax aspects of a possible annexation of Greenland by the United States.

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EU Envoys Fail to Reach Agreement on DAC9

Once again, EU member states couldn’t agree on how to make future updates to the ninth directive on administrative cooperation, which transposes the OECD's standard global minimum tax information return into EU law.

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Business Groups Call for U.S. Action at WTO on Digital Taxes

The United States should act at the WTO level to push back against other countries’ digital services taxes and similar measures that extract revenue from U.S. exports of digital products and services, business groups said.

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China Targets U.S. Farm Products With Retaliatory Tariffs

China has responded to President Trump's decision to implement new tariffs against Chinese imports by targeting American imports with a second round of retaliatory tariffs that threaten to disrupt agricultural trade.

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Long-Dormant Provision Complicates Tax and Trade Landscape

President Trump’s desire to use section 891 as a tool for international trade negotiations will require countries and their tax administrations to evaluate the tax and trade landscape.

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Opinion: Tariffs and the Slowing Economy

Tariff uncertainty and business caution are hitting first-quarter growth.

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Big Tech SEC Filings Tell Two Different Stories, Redux

Martin A. Sullivan examines the most recent Big Tech SEC filings, showing that many of those companies persist in keeping large portions of their profits outside the United States.

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Amount A: Revise, Restart, or Ditch?

Mindy Herzfeld examines options for amount A going forward.

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Trump’s Ambiguous Statements Throw EU Observers Off Balance

The Trump administration’s executive order disengaging from the OECD’s global tax plan and threatening retaliatory measures describes some actions that have never been taken and are legally questionable, further fueling global uncertainty, observers said.

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Customs Valuation Examples Under Trump’s Tariff Threat

J. Harold McClure analyzes the customs valuation for three different examples of popular imports under President Trump’s tariff regime.

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No Need for Panic on Pillar 2, EU Official Says

The problems raised by the United States regarding pillar 2 of the global tax plan are largely technical in nature and can be fixed, a senior European Commission official said.

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G20 Ministers Note Sovereignty Amid Global Tax Deal Talks

G20 members have observed recent progress on the OECD’s two-pillar global tax plan, recognizing countries’ autonomy while backing quick adoption of the reforms, according to a summary of a key G20 meeting.

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Beyond Tariffs: Should Trump Revive the DBCFT?

Robert Goulder connects the dots between President Trump’s affinity for tariffs and the border adjustment available under the destination-based cash flow tax.

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The Effect of Digital IP on Taxation and Transfer Pricing

Paul Glunt, Andrew Vickrey, and Jack O’Meara highlight examples of the digital transformation that is creating transfer pricing issues for multinational enterprises unique to the transfer or licensing of digital intangible property, and explain how investments in digital can address these issues and create value.

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G20 Leaders Summarize Key Meeting on OECD’s Two-Pillar Solution

The G20 issued a summary of the February 26-27 meeting of finance ministers and central bank governors regarding the progress of implementing provisions within the OECD's two-pillar global tax reform solution, expressing support for international tax policy cooperation within the parameters of member jurisdictions' autonomy and compliance with the OECD's standards and voicing concern over developing countries' difficulty in benefiting from international tax changes.

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When It Comes to Tariffs, Trump Can’t Have It All

The president has promised big results, from raising revenue to reviving domestic manufacturing. But many of his goals undermine one another.

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The U.N. Tax Convention Eyes Dispute Resolution

Nana Ama Sarfo explains how dispute avoidance and resolution has consistently played a role in discussions involving the U.N.'s framework convention on international tax cooperation

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OECD Working Paper Recommends Targeted Capital Gains Tax Relief

OECD countries should offer targeted capital gains tax relief instead of broad relief in order to decrease tax avoidance opportunities and discourage asset holding to delay tax payment, according to an OECD working paper.

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Lesson Plan: Analyzing Trump’s Approach to Tariffs

President Trump has been pushing tariffs in the first weeks of his new term. What are tariffs? How do they work? Are they good policy? We explore these questions, and others, in this lesson.

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Trump Plans Another 10% Tariff on Products From China

The U.S. next week will impose an additional 10% tariff on imports from China over its role in the fentanyl trade, the president said.

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White House Memo Promises Action Against Foreign Taxes

The Trump administration will respond to discriminatory taxes by foreign governments by imposing tariffs “and taking such other responsive actions necessary to mitigate the harm to the United States and to repair any resulting imbalance,” the White House said in a February 21 memo.

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Earnings Calls Are Disappointingly Quiet on Pillar 2

Martin A. Sullivan examines transcripts of multinationals’ earnings calls and SEC filings to update previous reports on how large corporations discuss the potential effects of pillar 2.

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Trump Issues Directive Aimed at Foreign Digital Services Taxes

President Trump formally requested that administration officials examine whether to impose tariffs on countries that charge digital services taxes on American companies.

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Let’s Note Overthink This: Recharacterization Under the OECD Guidelines

Michael McDonald provides context for the base erosion and profit-shifting 1.0 initiative regarding recharacterization and evaluates whether its objectives have been met.

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Consolidated Report on Amount B

The OECD has published a document that consolidates the report on the amount B transfer pricing simplification approach with related materials released throughout 2024, including a model competent authority agreement.

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Businesses Are Betting on a Tax Cut Extension

The federal budget debate has big implications for the economy. Despite questions about the math, investors expect an extensions of the 2017 tax cuts.

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Reciprocal Tariffs: Making Sense of Trump’s Hang-Up With VAT

Robert Goulder comments on the Trump administration’s push for reciprocal tariffs.

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Transfer Pricing and Tariffs: Finding Certainty in Trade Uncertainty

Allen S. Braddock examines the history of tariffs and how transfer pricing may be used to mitigate their effects.

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What Is an Applicable Corporation Under the Corporate AMT?

Kimberly S. Blanchard explains why section 59(k) and the proposed regulations are unclear and suggests an alternative, straightforward approach to the rules for foreign-parented multinational groups.

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Trump Weighs Tariffs to Counteract Foreign Taxes on Tech Firms

An executive memo takes aim at a major technology industry concern.

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Trump Floats 25% Tariffs on Autos, Chip and Pharmaceuticals

The president provided further details about his expected tariff moves.

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How Trump’s Tariffs Could Reorder Asia Trade and Exclude the U.S.

Asian countries are among the most vulnerable to President Trump’s economic grievances. But they are also best placed to make deals to minimize their exposure.

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Reports of Pillar 2’s Death Are Greatly Exaggerated

Adam Kern examines President Trump’s executive memorandum on the global tax deal, arguing that it will have a limited effect on the stability of pillar 2 because the United States maintains the global intangible low-taxed income structure and the strategic dynamics that support pillar 2 thus remain largely intact.

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IRS’s Periodic Adjustment Shift May Cause International Friction

Ryan Finley explains why the IRS’s new approach to periodic adjustments will likely bring the United States into greater conflict with its treaty partners.

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EU to Consider Factoring Global Trends in Decluttering Agenda

The EU Council’s Polish presidency will ask member states whether to include international tax developments in their draft conclusions on a “future-proof tax policy which contributes to the competitiveness of the EU.”

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Trump, Harley-Davidson, and the EU: A Tale of Tariff-Skipping Gone Wrong

Robert Goulder comments on the recent tariff-skipping decision in Harley-Davidson v. Commission.

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Sovereignty, Sins, and the Reassertion of Primary Taxing Rights by the United States

Michael J. Graetz argues that the United States must reassert its primary taxing rights over income long conceded to other countries, especially income from intellectual property created in the United States, and he explains some changes necessary to make that happen.

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EU Commission Answers Questions on U.S. Tariff Policy

The European Commission released a Q&A document regarding the United States' reciprocal tariff policy, including guidance on VAT in relation to tariffs; the EU's trade surplus rules; average tariff rates on both EU and U.S. imports; and asymmetrical tariff structures.

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