2023

The National Association of Manufacturers is calling on Congress to stop the scheduled taxpayer-adverse adjustments to rates for key international tax provisions of the Tax Cuts and Jobs Act set to take effect after 2025.

It shouldn’t be "Mission Impossible" to persuade the United States to amend its minimum tax so the EU won’t have to apply the undertaxed profits rule to U.S. companies, a top EU tax official said.

Jurisdictions implementing the amount B transfer pricing simplification framework should carefully analyze distributors within their borders before setting the upper bound of a key criterion for identifying in-scope distributors, a South Centre tax brief says.

It’s unlikely that Puerto Rico will be able to introduce a qualified domestic minimum top-up tax in line with OECD pillar 2 rules because of its tax decree regime, business stakeholders told the island’s Treasury.

Former OECD tax director Pascal Saint-Amans said the EU should seriously debate profit allocation among member states after the Apple state aid decision and the standstill on pillar 1 of the OECD’s global tax plan.

A clampdown on global corporate tax dodging turned Ireland into the nouveau riche man of Europe.

The American Chamber of Commerce in the EU has written again to the Romanian Ministry of Finance, warning that its early implementation of mandatory public country-by-country reporting throws into question the country’s “commitment to competitiveness.”

Sol Picciotto and Muhammad Ashfaq Ahmed argue that it is time for countries to move toward using the formulary apportionment method for taxation of multinationals and focus on Pakistan to show how this could be done, in concert with other willing countries, based on standards now agreed to by the BEPS inclusive framework as part of its two-pillar solution.

The widespread tariffs touted by President-elect Trump during his campaign could raise prices and draw global retaliation, leading to additional costs for American consumers and importers.

José de Campos Amorim explains how recent Portuguese tax legislation presents a series of tax benefits for business development by reducing the tax burden and attracting investment in various sectors of the economy.

Mindy Herzfeld examines digital services taxes and the role U.S. retaliatory measures against them might play in a world of more comprehensive tariffs.

The ninth EU directive on administrative cooperation, a proposed framework for exchanging multinational entities’ pillar 2 information between member states, will substantially reduce reporting, according to a top tax official on the European Commission.

While global emissions coverage by carbon pricing instruments appears to have stalled in recent years, emissions trading systems under development are expected to substantially expand that coverage, according to a new report.

Reuven S. Avi-Yonah and Nessa Ní Chasaide argue that the EU's Court of Justice was misguided in the recent Apple ruling, which raises significant issues relating to the legal governance of corporate tax.

A second Trump administration, a Republican-controlled Senate, and recent actions by Republican lawmakers are likely signs that implementing the OECD’s two-pillar global tax reform plan is about to become much more challenging, observers say.

Could a tariff war erupt between the United States and Mexico? A top Mexican official said his country might retaliate if the Trump administration placed steep tariffs on Mexico.

Wopke Hoekstra, EU commissioner-designate for taxation, said the bloc will have to reconsider digital taxation if an international solution to issues blocking pillar 1 can't be found in the wake of President-elect Donald Trump's reelection.

The EU is better prepared to respond to President-elect Donald Trump’s tax and tariff threats than it was in 2016, but the bloc is still bracing for four challenging years.

Elizabeth J. Stevens and H. David Rosenbloom provide an overview of how U.S. tax policy enabled multinational enterprises to use cost-sharing arrangements to their disproportionate gain, with still-reverberating consequences for global tax policy.

The Kenyan government has reintroduced draft legislation in Parliament that would repeal the country’s digital services tax in favor of a significant economic presence tax and implement global minimum tax rules.

Ruth Mason and Stephen Daly take an in-depth look at the Apple state aid case at the EU’s Court of Justice, pointing out how it is deeply flawed and explaining the role Irish and U.S. tax law combined to play in facilitating Apple’s tax planning.

Mindy Herzfeld examines how each presidential candidate might steer international tax policy.

An IRS official has expanded on what to expect, and what not to expect, from a long-awaited package of rules concerning previously taxed earnings and profits expected by the end of December.

The Puerto Rican government does not plan to enact pillar 2 global minimum tax legislation that would void the constitutionally protected tax agreements that it has with multinational enterprise groups, according to an official.

Wopke Hoekstra, commissioner-designate for climate, net zero, and clean growth, will be the EU’s next tax figurehead, but observers are scratching their heads over his agenda because taxation hasn't been uppermost in his political career.

A permanent safe harbor under the OECD global minimum tax rules makes sense, and the European Commission is hopeful that it will be finalized soon, a top tax official said.

A U.N. official has expressed concern regarding the global shift toward implementing digital services taxes, asserting that they violate countries’ treaty obligations because they are essentially income taxes.

Current treaty provisions limiting access to mutual agreement procedures to resident taxpayers should be expanded to consider requests by companies under controlled foreign corporation regimes or subject to upcoming pillar 2 rules, an IRS official said.

Although the co-chair of the OECD inclusive framework on base erosion and profit shifting remains hopeful for a final pillar 1 tax agreement, its members are disappointed that it hasn’t happened yet.

Treasury is taking the reins on creating a comprehensive tax agreement with Taiwan after the House and Senate started legislative efforts to relieve double taxation.

A new EU legislative proposal would create a framework to exchange pillar 2 information from multinational entities among member states and with non-EU jurisdictions.

A newly approved article amending rules on cross-border fees on services in the U.N. model tax convention will be good for developing countries, but its controversial nature may hinder its implementation, a tax professor said.

Fair tax policies must take into account the increasingly contentious battle for taxing rights in the digital economy and the growing momentum of a U.N. tax convention, South African Revenue Service Commissioner Edward Kieswetter said.

Leopoldo Parada explains the development of an international forum for the creation of a more inclusive international tax regime; he focuses on developments at the U.N. and relates them to OECD developments in this area.

The former president has repeatedly praised a period in American history when there was no income tax, and the country relied on tariffs to fund the government.

The French National Assembly will soon discuss proposed amendments to the 2025 draft finance bill, which would increase France’s controversial digital services tax by at least 2 percentage points to raise much-needed revenue.

Wopke Hoekstra, EU commissioner-designate for taxation, told members of the European Parliament that while nearly all multinational enterprises will pay the global minimum tax under pillar 2 by 2025, the system is still at risk.

An estimated 90% of large multinational companies in scope of OECD rules will be subject to the minimum tax regime in 2025, the organization told G-20 ministers in a Thursday report.

An environmental committee of the European Parliament has adopted a set of demands for the upcoming U.N. Climate Change Conference that call on the European Commission to push for carbon pricing outside the bloc.

Doron Narotzki explores the resurgence of high tariffs in U.S. trade policy, beginning with the Trump administration and continuing into the Biden administration, that were initially intended to protect domestic industries and reduce trade deficits, but have instead led to increased consumer prices, strained diplomatic relationships, and harmed global trade dynamics.

Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler review the extensive proposed corporate AMT regs, explain the ongoing effect of Loper Bright, review comments on stock buyback regs, and offer updates on the Treasury Inspector General for Tax Administration’s economic substance doctrine report, taxpayers’ compliance assurance process eligibility, and IRS advice on foreign-derived intangible income and 245A dividends received deductions.

Lee A. Sheppard examines the recently released dual consolidated loss proposed regulations.

Mindy Herzfeld examines the increasing complexities that multinational corporate taxpayers face in light of the recently released proposed corporate alternative minimum tax regulations, including the significant differences between accounting and income tax treatment of income.

Margrethe Vestager, executive vice president of the European Commission and commissioner for competition, told members of the European Parliament that the global community should keep working on pillar 1 and on an alternative.

Reuven S. Avi-Yonah explains the relationships between Chinese tax policy, pillar 2, and global multinational enterprises.

American groups and lawmakers are rallying behind a legal challenge filed in Belgium’s Constitutional Court against the undertaxed profits rule, but it could be a while before a decision is rendered — and success isn’t guaranteed.

Paul Poliakov explains how resolving double taxation and other inefficiencies of the U.S. domestic law regime for taxing foreign corporations could improve Taiwan-U.S. business relations.

Kartikeya Singh, Anthony Tufo, Shubhana Sattar, and Marco Fiaccadori explain the OECD inclusive framework’s amount B and the large effect it is likely to have on transfer pricing. They analyze the ways in which multinational enterprises can prepare for the various iterations that could arise as jurisdictions choose how to react to amount B.

David Farhat, Mayowa Olujohungbe, and Bryan McGrane explain why tax authorities can and should expediently address base erosion and antiabuse tax liability that may arise from taxpayers’ use of the advance pricing and mutual agreement program.

The Irish Department of Finance has issued draft legislation calling for amendments to existing laws to implement the OECD amount B political commitment and incorporate further global anti-base-erosion administrative guidance.