Will Trillions in Tariff Revenue Materialize?
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.
Countries Ready for U.N. Tax Talks Despite U.S. Exit
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.
European Commission Issues Statement on U.S. Tariff Policy
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."
BIAC Responds to PCT Tax Incentives Principles Consultation
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.
Trump's Plan to Exit OECD Deal Threatens Two Canada Tax Rules
The future of Canada’s digital services tax and proposed undertaxed profits/payments rule—and possibly its approach to Pillar Two and international tax more broadly—is precarious in the face of international trade pressures and the Trump administration’s threats about the OECD’s global tax deal.
Why Trump Tariff Push Is Targeting Value-Added Taxes: Explained
President Donald Trump doesn’t like other countries’ value-added taxes. Trump said Thursday that his administration would look at imposing “reciprocal” tariffs against other nations. They would be aimed at offsetting not only the tariffs those countries charge on US goods, but also other regulatory and tax measures that Trump regards as unfair to the US—including VATs, which many countries impose on the sale of goods and services.
Trump’s Reciprocal Tariff Plan Targets European VAT
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.
Trump Moves to Impose Reciprocal Tariffs as Soon as April
President Donald Trump ordered his administration to consider imposing reciprocal tariffs on numerous trading partners, raising the prospect of a wider campaign against a global system he complains is tilted against the US.
EU Commission Goes Back to Drawing Board on Interest, Royalties
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.
EU Is Attempting to Sidestep U.S. Steel Tariff Snares
EU lawmakers have denounced the weaponization of economic policy by the new U.S. administration, and the European Commission has promised a firm response to President Trump’s announced tariffs on EU steel.
UN Tax Talks Persist Despite Trump’s Hard Line on Global Deals
The Trump administration’s rejection of multilateral tax deals has strengthened the resolve of nations driving negotiation of a new tax treaty at the United Nations, while forcing others to rethink their strategies.
Cloud Computing, DPL Regulations, and Other Administrative Guidance
Larissa Neumann, Mike Knobler, and William R. Skinner review the large amount of guidance released at the end of the Biden administration, including guidance on cloud computing transactions, disregarded payment loss regulations, and several chief counsel advice documents.
EU Tax Commissioner Vows to Keep an Open Mind on Pillar 2
The EU will not deviate from its course regarding pillar 2 but would enter any possible OECD talks on a permanent safe harbor for U.S. companies with an open mind, Tax Commissioner Wopke Hoekstra said.
Countries Agree to Majority Decisions for U.N. Tax Convention
After days of deliberation, countries finally agreed to make decisions on a U.N. tax framework convention by simple majority, with a two-thirds majority needed to approve any protocols to the convention.
AEI Paper Recommends High-Tax Exclusion for GILTI Reform
Implementing a mandatory high-tax exclusion so global intangible low-tax income would apply only to income below the exclusion threshold could reduce tax avoidance, raise revenue, and be relatively simple to implement, according to a February report released by the American Enterprise Institute.
Practicality of Carbon Border Adjustment in a Carbon Tax
Shuting Pomerleau compares two methods used to border-adjust a carbon price, arguing that border adjustments present unique challenges but, if designed well, would be an important part of a domestic carbon price in the United States.
Past Their Prime: Updating the FTC Noncompulsory Rules for the Pillar 2 Era, Part 1
David J. Sotos and J.P. Gregorcy, in the first in a two-part series, examine the history of noncompulsory payment rules under reg. section 1.901-2(e)(5) and identify areas that need clarification in light of pillar 2.
Significant Economic Presence Taxation: A Concept Without Practice?
The International Tax and Investment Center explains the concept of significant economic presence and shows the outcome of efforts by the OECD inclusive framework to develop a new net-basis taxation with parallels to the existing physical presence.
Canada Responds to U.S. Tariffs With 25 Percent Tariffs
Canada's Department of Finance issued a release February 1 announcing that the government will impose 25 percent tariffs on U.S. goods worth C $155 billion in response to the U.S. tariffs imposed on Canadian products, noting that the government will continue to consider additional, non-tariff-related countermeasures.
EU Still on Fence About Future Changes to Pillar 2 Info Exchange
EU member states have not yet resolved the issue of how to quickly introduce any future changes to the OECD's standard global anti-base-erosion information return, which is implemented through the administrative cooperation directive.
EU Faces Make-or-Break Moment at U.N. Tax Talks
Negotiations for a U.N. framework convention on international tax cooperation are slated to begin in February, and key organizational decisions could further alienate EU member states that do not want to duplicate the OECD’s work.
Digital Tax Surveillance: Allowing an All-Seeing State
Lyla Latif reconceptualizes modern tax administration through the lens of surveillance studies, demonstrating that tax studies must expand beyond efficiency to address fundamental questions about individual autonomy and the boundaries of legitimate oversight in a digital age.
The U.N. Model Tax Convention’s Attempt to Override Investment Treaties: A Critical and Normative Assessment
Robert Danon and Adolfo Martín Jiménez examine the new model clause for article 25 of the U.N. model tax convention, arguing against introducing it in double tax treaties because it is inconsistent with modern investment treaty policy and a "whole of government" approach and raises several problems under international law.
EU Still on Fence About Future Changes to Pillar 2 Info Exchange (1)
EU member states have not yet resolved the issue of how to quickly introduce any future changes to the OECD's standard global anti-base-erosion information return, which is implemented through the administrative cooperation directive.
EU Faces Make-or-Break Moment at U.N. Tax Talks (1)
Negotiations for a U.N. framework convention on international tax cooperation are slated to begin in February, and key organizational decisions could further alienate EU member states that do not want to duplicate the OECD’s work.
High Stakes for Global Companies in Trump’s Latest Tariff Threats
According to a U.S. official, challenges in global anti-base-erosion (GLOBE) rules negotiations under the OECD's pillar 2 taxation framework have made a permanent safe harbor provision seem unlikely.
H.R. 591 Would Impose Reciprocal Taxes on Foreign Countries
H.R. 591, the Defending American Jobs and Investment Act, introduced by House Ways and Means Committee Chair Jason Smith, R-Mo., would impose reciprocal taxes on the U.S. income of companies and investors in foreign countries that impose extraterritorial or discriminatory taxes on U.S. businesses.
Eurozone Economy Stagnates as It Braces for Fresh Blow From Tariffs
The economy returned to stagnation as 2024 drew to a close, a blow to its hopes for a recovery as it braces for the possibility that Trump will deliver a long-threatened increase in tariffs.
OECD, Latin American Partners Work to Improve Tax System Trust
The OECD and its partners in Latin America are working to improve low trust in the tax system through better communication, digitalization, and shifting tax authorities from an enforcement to a service model.
Multilateralism or Bilateralism in Building a Tax Treaty Network: A Comparison
P.V.S.S. Prasad explains the difficulties of reaching multilateral agreements among jurisdictions with varying tax and economic policies, and he argues that bilateralism will remain prominent because it avoids those difficulties while still allowing negotiators to address their specific concerns.