2023

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

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.

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.

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

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.

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.

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

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

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.

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.

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.

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.

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.

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

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

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.

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

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

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

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.

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

The president provided further details about his expected tariff moves.

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.

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.

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.

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.”

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

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.

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.

Martin A. Sullivan examines available data to provide insight on the economic effects of potential tariffs on U.S. imports, and he categorizes the strategies companies have considered for mitigating the burden of tariffs.

Mindy Herzfeld examines the potential impact of President Trump’s recently announced tariffs and offers alternatives that could be less disruptive to the U.S. economy.

Countries worldwide appear optimistic about participating in negotiations for a U.N. framework convention on international tax cooperation, despite the United States’ swift exit from the talks in early February.

Lucas de Lima Carvalho explains his proposal for a single virtual jurisdiction in the development of the taxation of artificial intelligence.

The European Commission has issued a statement regarding the announced U.S. tariff policy, saying it would have negative economic effects and promising that "the EU will react firmly and immediately against unjustified barriers to free and fair trade."

Business at OECD issued a letter responding to the Platform for Collaboration on Tax's (PCT) public consultation on its guidance for tax incentives principles for international policy purposes and introducing the OECD's global minimum tax standard, urging the PCT to lighten restrictions regarding tax incentive definitions and jurisdictional autonomy as well as provide explicitly clear pillar 2 guidance.

President Trump has ordered advisers to craft new tariffs for countries that have a trade deficit with the United States by calculating all costs related to trade barriers and subsidies provided to domestic corporations.

Reuven S. Avi-Yonah explains why concerns about the risks associated with publicly disclosing country-by-country reports are exaggerated and that the benefits outweigh the costs.

The European Commission has announced the withdrawal of its proposal to revise the interest and royalty directive, which was made partially obsolete by pillar 2, and is now looking at aligning EU antiabuse clauses.

How is it in America’s national interest to let other countries decide what duties we pay?