2023

Reuven S. Avi-Yonah, Jeffery M. Kadet, and Karen Sam refute certain criticism of the proposed cloud services sourcing rules released in January, and they suggest important amendments for Treasury and the IRS to consider in implementing the final regulation.

Craig A. Hillier and Yulia Kirillova review the status of pillar 2 in light of U.S. opposition and they suggest ways to adjust the structure to accommodate the concerns of the United States and other nations while maintaining some of its benefits.

More than two dozen countries criticized a system that would exempt American multinational companies from key parts of the global minimum tax, saying it would risk undermining the tax’s effectiveness, put non-US companies at a disadvantage, and challenge their own tax sovereignty.

US President Donald Trump threatened to impose fresh tariffs and export restrictions on advanced technology and semiconductors in retaliation against other nations’ digital services taxes that hit American technology companies.

Mindy Herzfeld argues that despite the Trump administration’s strong stance against foreign discriminatory taxes, it hasn't taken serious action against them, and says that the administration’s recent deal allowing manufacturers to export AI chips to China closely resembles the types of taxes it disapproves of from other countries.

U.N. countries have very different — and sometimes oppositional — approaches to allocating taxing rights in a digitalized economy, which could complicate negotiations around cross-border services taxation, according to a recent report.

The International Centre for Tax and Development on August 7 issued a policy brief regarding the trade-offs in the U.N. negotiations for protocol 1 to the framework convention on international tax cooperation, finding that protocol 1 needs to address ongoing cross-border taxation issues as digitalization rises; that tax policymaking must be intentional; and that the United States' exit from OECD negotiations limits the potential of a comprehensive international tax standard.

As data centers become a crucial part of global digital infrastructure, revenue authorities worldwide are increasing scrutiny of how such operations may be taxed.

Building a better tax system in Australia is one of the 10 longer-term reform priorities announced by Treasurer Jim Chalmers following a highly anticipated productivity summit with key stakeholders.

Robert Goulder comments on the unexpectedly high U.S. tariffs imposed on Swiss imports.

The OECD has proposed a range of tweaks to the global minimum tax agreement in a bid to quell US concerns about how the regime affects American companies.

Since January 2025, the Trump Administration has raised tariffs on US imports to their highest average levels in recent history, from a universal 10% tariff on virtually all goods imported into the US to a threatened 145% on goods imported from China and varying levels of “reciprocal” tariffs on dozens of additional countries. These tariffs include 25% tariffs on products deemed noncompliant by the administration with the US-Mexico-Canada Agreement (USMCA) update to the North American Free Trade Agreement and 25% tariffs on steel, aluminum, and auto-related products. Other planned tariffs include pharmaceuticals, copper and copper derivatives, semiconductors, and timber and lumber. Further, the US faces retaliatory tariffs from several countries and the European Union.

Treasury and the IRS have decided to withdraw the rules applying disregarded payment losses after concerns about statutory authority led to rounds of delays and additional carveouts.

The U.N. tax committee is looking for input on which tax policy issues it should focus on during its next five-year term.

The One Big Beautiful Bill Act’s suite of international tax reforms is likely to spur a surge in tax insurance activity as companies model out the new provisions and stake out uncertain new positions, insurers say.

A Slovakian minister said he intends to present a proposal to the country’s coalition government to impose a tax on large multinational companies providing digital services in Slovakia.

Daniel N. Shaviro compares the broad effect of digital services taxes and the OECD’s pillar 1, asking whether the emergence of the former in lieu of the latter is an unforeseen benefit to the United States.

Several country representatives have expressed support for the creation of a cooperative transfer pricing comparables database under a key protocol to the U.N. framework tax convention, but others warned the task wouldn’t be easy.

The IRS and Treasury are contemplating the proper attribution method to determine the source of income for cloud transactions and are questioning how to evaluate relevant factors like intangible property.

The OECD plans to adapt its transfer pricing guidelines to new realities like global mobility and artificial intelligence and to develop a common understanding of terms that are often disputed, an official said.

The lines between tax and trade policy are likely to become increasingly blurred as the Trump administration shifts its attention to disarming overseas digital services taxes, observers say.

The U.N. tax framework convention’s early protocol on services should incorporate fractional apportionment or formulary apportionment similar to amount A of pillar 1 of the OECD’s two-pillar global tax reform plan, the G24 said.

The design of an own resource to finance the EU budget as a contribution levied on high-turnover companies raises legal questions.

Pramod Kumar Siva and William H. Byrnes explain why the UTPR, formerly known as the undertaxed profits rule, is an unlawful extraterritorial tax that contravenes legal norms, generates economic distortions, and diminishes international tax cooperation.

A new Eurobarometer shows that 80 percent of Europeans polled want large multinational enterprises to pay a minimum amount of tax in each of their countries of operation, an idea that finds a majority in all member states.

Muhammad Ashfaq Ahmed examines changes to the U.N. Model Tax Convention 2025 from their genesis, evolution, and development, to their finalization, approval, and future implications from both an international tax law and international political economy perspective.

Mindy Herzfeld examines the developments that led to the recent G7 agreement to respect the U.S. tax regime as “a side-by-side system” with the OECD’s pillar 2 and what that means for the future of digital services taxes and tax multilateralism more broadly.

The EU has “a quite negative view” on the United States' proposal to credit its minimum tax rules when calculating their qualified domestic minimum top-up taxes under pillar 2, according to a top European Commission official.

In a letter to the editor, Jefferson VanderWolk argues that pillar 2 should be abandoned rather than an attempt be made to salvage it.

Nana Ama Sarfo discusses Nigeria's new tax reform legislation and its emphasis on base broadening and tax enforcement.

Robert Goulder comments on the recent G7 agreement regarding pillar 2 and the withdrawal of proposed section 899.

Governments across the globe breathed a sigh of relief when Republicans dropped section 899, but slow progress on the terms of the deal reached by the G7 could see it return with a vengeance.

Germany’s economy minister has rejected the idea of imposing a digital tax on U.S. technology companies that the minister of state for culture had said the government was drafting in May.

Irish Finance Minister Paschal Donohoe said there are still outstanding questions about how the G7 deal on pillar 2 will affect competition between the EU and the United States and the future of the law.

The European People’s Party's advocate for copyright issues in the European Parliament has suggested a 7 percent levy on artificial intelligence companies that use copyright-protected works to compensate rightsholders.

BRICS member states said they support work on a U.N. tax convention and its role in promoting better cooperation and transparency to address issues like illicit financial flows and tax evasion by the superrich.

Simone Decè considers whether implementing a global wealth tax is practical, analyzing the challenges that different proposed solutions present.

Martin A. Sullivan examines the foreign-derived deduction-eligible income provision in the reconciliation bill.

Several high-income countries and civil society groups committed to improving developing countries' domestic tax systems to increase revenue collection there at a major U.N. development financing conference.

Lucas de Lima Carvalho examines the status of the OECD’s multilateral instrument in Argentina and Peru.

Nana Ama Sarfo reviews the tax-related provisions of the outcome document from the U.N.'s Fourth Financing for Development Conference and the Sevilla Platform for Action.

 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.