2023

 Foreign investors that reinvest their dividends from Chinese entities into qualifying domestic companies will be allowed a 10 percent tax credit, the government announced June 30.

Shafi U. Khan Niazi and Richard Krever examine how the European Commission attempted to stop intra-Europe transfer pricing schemes by reversing private rulings that facilitated profit shifting through preferential tax treatment in the profit destination jurisdictions.

The European Commission says the G7 provisional agreement on pillar 2 is based on a permanent safe harbor shielding U.S. firms, but the lack of details leaves stakeholders drawing various conclusions.

The U.N. committee negotiating a framework convention on international tax cooperation will focus on the fair allocation of taxing rights — especially over multinationals — and the prevention and resolution of tax disputes at its next sessions.

Guy A. Bracuti examines President Trump’s Executive Order 14269, “Restoring America’s Maritime Dominance,” and the tax provisions of the Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025.

The United States’ G7 counterparts have agreed to not apply their pillar 2 global anti-base-erosion (GLOBE) rules to U.S.-parented groups, but those companies would still be in scope of qualified domestic minimum top-up taxes.

Canada will rescind its digital services tax as part of its efforts to continue trade negotiations with the United States, Canadian Prime Minister Mark Carney said June 29.

HM Revenue & Customs welcomed the removal of the section 899 revenge tax in the U.S. One Big Beautiful Bill Act (H.R. 1), adding it hopes to publish new U.K. pillar 2 guidance in July.

Wei Cui argues that the One Big Beautiful Bill Act’s formerly proposed section 899, targeting “unfair” foreign taxes, was more sensible than many observers initially perceived, and that, if seen as a restrained deployment of U.S. market power, it represented a defensible and ultimately acceptable approach for addressing the undertaxed profits rule and digital services taxes.

Mindy Herzfeld examines the changes made by the Senate to some provisions of the One Big Beautiful Bill Act, saying that the Senate’s version of the bill improves on the retaliatory tax measures introduced by the House and would simplify and improve the U.S. international tax regime.

The Chinese government has issued a decree regulating tax-related information that internet platform companies are required to submit.

Stephen L. Curtis continues his analysis of PayPal’s cost-sharing arrangement, explains how the cost-sharing regulations can be exploited to possibly shift billions in U.S. profits offshore with little or no IRS detection or enforcement, and explores how the agency’s position could be changing.

Employees are increasingly on the move in the wake of the COVID-19 pandemic, and observers say the OECD is well placed to design templates to make it easier for countries, companies, and employees to determine tax residency.

Raffaele Petruzzi and Argyro Myzithra explore the implications of remote working arrangements for a multinational enterprise's permanent establishment and its transfer pricing issues.

EU finance ministers adopted a progress report on tax issues and deleted several of its points on pillar 2 of the global tax deal, including the need for its implementation worldwide.

Senate Republicans addressed key concerns about the scope of a proposed excise tax on remittances in their version of the reconciliation tax bill, but the overarching policy still has its detractors.

A portion of the ‘one, big, beautiful bill’ could lead to a new tax on foreigners’ U.S. investments in private equity and credit. Some of them are treading cautiously.

Robert Goulder comments on the practice of duty drawbacks and a recent legislative proposal to limit their reach.

A loophole in Trump’s policy bill would continue to encourage offshoring.

Senate Republicans unveiled a robust set of international corporate tax reforms in their version of the reconciliation tax bill, including adjustments to the House-passed version and a suite of new provisions.

Members of the European Parliament rejected a report calling for a strong U.N. tax process in the context of the next international conference on financing development, though that specific provision was consensual.

U.N. countries agreed to prioritize international tax cooperation ahead of a major development financing conference, with an emphasis on improving domestic resource mobilization for developing countries.

 Oliver R. Hoor explains the relationship between taxation and inflation.

The EU Council's Polish presidency urged the European Commission to revise its plan to fund the bloc's budget after member states pushed back on the current package of proposed levies yet again.

Nina E. Olson compares a Dutch program that used artificial intelligence to identify fraudulent child care subsidy claims to the IRS Criminal Investigation division’s questionable refund program and warns that trends in U.S. tax administration could lead to similar violations of taxpayer rights.

Reuven S. Avi-Yonah explains the three primary goals of taxation — revenue, redistribution, and regulation — and shows how VAT, the individual tax, and the corporate tax each uniquely match one of the goals.

Mindy Herzfeld examines some provisions of the One Big Beautiful Bill Act that could have adverse economic effects.

The European Commission is asking for feedback on tax incentives and simple tax procedures for its upcoming recommendation on establishing savings and investment accounts to drive individual participation in capital markets.

 Irish government estimates that corporate tax revenue is likely to remain unchanged because of pillar 2 through 2026 are not credible and ignore evidence that revenue could increase, according to the country’s fiscal watchdog.

Katherin Díaz Velilla explains why, despite inconsistent tax standards and policy implementation, there is a global trend toward greater substance requirements.

Pramod Kumar Siva explores the potential benefits and challenges of a greater role for AI in tax administration.

The Congressional Research Service in a June 9 report summarized provisions in the House-passed version of H.R. 1, the One Big Beautiful Bill Act, that would raise taxes on U.S.-sourced income of nonresident aliens from countries imposing allegedly discriminatory taxes such as digital services taxes and the OECD pillar 2 undertaxed profits rule.

The short answer is probably not, according to multiple forecasters.

Mauritius plans to introduce a qualified domestic minimum top-up tax on resident subsidiaries and holding companies of multinational enterprises that are resident in the country.

Switzerland has approved a formal proposal to automatically exchange cryptoasset tax information with 74 partner jurisdictions, including the EU member states and most G20 countries, beginning in 2026.

Abe Zhao examines trends in China’s evolving tax enforcement policies and offers practical insights for multinationals navigating increasingly sophisticated and assertive tax audits in China.

Lee A. Sheppard examines the potential effects of the the House budget reconciliation bill’s proposed section 899, which would increase taxes for residents of countries maintaining discriminatory taxes and modify the base erosion and antiabuse tax.

Although EU countries accept that decisions on a U.N. tax convention will happen by majority vote, they still feel the best way to guarantee success is through consensus, according to a Polish tax official.

Larissa Neumann and William R. Skinner review the One Big Beautiful Bill Act and the bill introduced by Senate Finance Committee member Thom Tillis, R-N.C. They also examine the IRS guidance memo on resource allocation for the advance pricing and mutual agreement program, developments with pillar 2, and the challenge to stock-based compensation in McKesson.

The European Commission is still waiting on select countries to address or commit to countering aggressive tax planning, despite toned-down economic recommendations from member states earlier this year.

Several aspects of the section 899 retaliatory tax in the House-passed tax bill raise red flags that the provision violates Senate procedures, which could lead to the tax being severely constrained or scrapped altogether.

The European Commission is signaling a potentially more ambitious review of its 2017 dispute resolution mechanism directive, according to a top EU tax official.

President Trump’s tariffs would raise $2.5 trillion in revenue over the next decade, but the cost to the economy would more than offset the total economic growth expected from the House bill’s tax cuts.

Several U.S. industry organizations, including the U.S. Chamber of Commerce and the National Foreign Trade Council, issued a letter to the U.S. trade representative and the secretaries for the U.S. Treasury and the U.S. Department of Commerce calling on the government to push back against the discriminatory digital services tax measures from Canada and the United Kingdom, noting that the Canadian DST will cost the United States up to $2.3 billion annually.

The UK is weighing the future of its Digital Services Tax (DST), under pressure from US trade threats. From the White House to the tech sector, the DST has been described as a discriminatory ‘tariff’ almost entirely targeting large US internet companies. No-one seems to have asked whether that’s actually true. New data obtained by TaxWatch show that nearly 40 percent of the companies subject to the UK DST are not headquartered in the US at all, contrary to claims made by politicians and the tech industry itself.

Treasury Deputy Secretary Michael Faulkender warned the OECD that the United States will retaliate if the group doesn’t accept several existing U.S. tax provisions as being compliant with a global minimum tax initiative.

Bermuda has started a public consultation on draft technical amendments to its corporate income tax regime to bring it more in line with OECD pillar 2 global minimum tax rules and related administrative guidance.

The OECD issued a release announcing that it has published its June 2025 economic outlook report, which analyzes the economic prospects of various member jurisdictions, noting that global economic growth is projected to slow down from 3.3 percent to 2.9 percent in 2025 and 2026 and that various factors could affect overall economies in the coming years, including inflation pressures, increased tariffs and high trade costs, high debt payments, and uncertain tax policies.

Danielle Rolfes, Alistair Pepper, Daniel Winnick, and Casey Caldwell analyze the revised versions of two proposed retaliatory tax measures, consolidated in proposed section 899, now before the Senate as part of the budget reconciliation package, assessing whether the more significant modifications to those now-combined proposals are consistent with Congress’s stated policy goals in responding to “unfair” taxes imposed by foreign countries.

Mindy Herzfeld examines the international tax provisions of the House reconciliation bill and considers how they could affect international investment in the United States.