Controlled Foreign Corporations as Collateral After the TCJA
Kevin M. Cunningham explores situations in which U.S. multinational borrowers might incur a section 956 inclusion as a result of using controlled foreign corporation stock or assets as collateral, and he describes the factors that must be evaluated when providing such collateral as well as the strategies that can be undertaken to avoid the inclusion.
Still No Easy Digital Tax Answers for Developing Countries
Nana Ama Sarfo reviews the latest research commissioned by the South Centre, African Union, African Tax Administration Forum, and West African Tax Administration Forum into the amount of revenue developing countries might raise from amount A versus a digital services tax.
Canada’s Enactment of Pillar 2 — Part I
Nathan Boidman, Michael N. Kandev, and Marc André Gaudreau Duval, in the first installment of a two-part analysis, provide an overview of, and context for, the Global Minimum Tax Act — legislation now moving through Canada’s Parliament to implement pillar 2. Part two will more closely examine certain aspects of the legislation with a focus on provisions that yield interpretational issues or deal with antiavoidance.
U.N. Makes Progress Toward a Framework Convention on International Tax Cooperation
Hafiz Choudhury explains efforts at the U.N. to foster an international taxation cooperation process more inclusive of developing countries. The opinions expressed in this article are solely those of the author and do not reflect the views of any other person or organization, in particular the U.N.