2023

Robert Goulder comments on replacement of the EB-5 visa program with a residency-for-sale scheme.

The Netherlands has asked the EU Code of Conduct Group on business taxation to set its sights on the tax treatment of wealthy individuals while the EU Tax Observatory sees its own tax proposal gaining traction.

The European Commission removed a plea for member states to drop opposition to the Debt-Equity Bias Reduction Allowance directive in its new savings and investments union plan.

The Alliance for Competitive Taxation issued a letter to U.S. Treasury Secretary Scott Bessent voicing support for the executive order pulling the United States out of the OECD global tax deal, emphasizing that the undertaxed profits rule under pillar 2 of the OECD’s two-pillar tax reform plan would cause the United States to lose an estimated $122 billion in tax revenue over the next decade.

As some EU member states and businesses ratchet up the pressure to put pillar 2 on pause amid global tax and trade tensions, EU Tax Commissioner Wopke Hoekstra said the bloc should stand its ground.

Michael McDonald analyzes whether a recent IRS generic legal advice memorandum affects the way the commensurate with income standard should be implemented compared with former guidance.

Mindy Herzfeld explains how recent U.S. tariff policy could be an opportunity for a reset of Canada’s tax policies toward U.S. multinationals.

The European Commission is not interested in establishing a coordinating group on transfer pricing that does not produce political commitment from member states or peer reviews, leaving talks on a joint platform at an impasse.

Reuven S. Avi-Yonah explains the relationship between recent executive orders and the Defending American Jobs and Investment Act with the debate over discriminatory international taxes.

Raffaele Russo and Gaia Maglione examine the future of international taxation following the withdrawal of support for the OECD global tax deal and the launching of the America First trade policy via Trump administration memoranda.

After the Trump administration’s decision to impose a 25 percent import duty on steel and aluminum, the EU plans to hit the U.S. president where it hurts, targeting Republican states with tariffs on their exports.

The Platform for Collaboration on Tax hopes to finalize in the coming weeks incentives principles to guide policymakers navigating an international landscape shaped by developments such as the OECD’s global minimum tax rules.

Libin Zhang examines section 891 and how it is limited by withholding tax statutes and U.S. income tax treaties.

Nana Ama Sarfo reviews the first year of the Regional Platform for Tax Cooperation in Latin America and the Caribbean.

Despite EU businesses’ increasing calls for a pause in pillar 2 talks, a senior EU official said the bloc will seek an agreement that considers both the U.S. and OECD rules on minimum corporate taxation.

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.

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.

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

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.

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.

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.

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.

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

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.

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.

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.

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.

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

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.

Mindy Herzfeld examines options for amount A going forward.

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.

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.