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2025

Brazil: Dividend Taxation and the Stock Market

Lucas Martini de Aguiar analyzes the potential impact of new Brazilian legislation on nonresident investment in the stock market.

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All Eyes on Pillar 2 ‘Quagmire’ as Treasury, IRS Draw Up Guidance

The tax guidance multinational corporations and international tax practitioners want to see most has nothing to do with the sweeping new tax law that was just enacted.

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G20 Reiterates Commitment to International Tax Cooperation

G20 finance ministers and central bank governors issued a communiqué following their July 17-18 meeting in South Africa, noting their continuing commitment to improving international tax cooperation by addressing concerns regarding global minimum taxes under pillar 2 of the OECD’s two-pillar global tax reform plan.

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EU Countries Give Cold Reception to Proposed New Levies

Several EU member states said it is not within the EU's competence to collect a financial contribution from companies to finance the bloc's budget and that such a measure would harm competitiveness.

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G20 Finance Ministers Vow to Find Common Ground on Pillar 2

The G20 will keep negotiations going on a proposal to shield U.S. companies from the application of some OECD pillar 2 global minimum tax rules, according to a communiqué issued after a key meeting.

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Faux CFCs and Restoration of the Prohibition on Downward Attribution

Lee A. Sheppard examines a provision in the One Big Beautiful Bill Act that restores, with some exceptions for specified foreign parent situations, the prohibition on downward attribution that the Tax Cuts and Jobs Act repealed, saying that the IRS and Treasury will need to rescind or reengineer guidance issued while the prohibition was repealed.

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Trade Deal Doesn’t Reconcile EU, U.S. Views on Network Fees

The White House says the EU is committed to abandoning its future plans to impose network fees on big U.S. tech platforms; the European Commission is less sure.

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OECD Updates G20 on International Tax Cooperation Developments

The OECD on July 17 published a report — prepared ahead of the July 17-18 meeting of G20 finance ministers and central bank governors in South Africa — regarding recent developments in international tax cooperation, including its support of various G20 priorities such as tax transparency and the implementation of the base erosion and profit-shifting minimum standards.

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Does the U.S. Exception Threaten Pillar 2?

Adam Kern analyzes how treating global intangible low-taxed income as an income inclusion rule will affect the stability of pillar 2.

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Is the U.S. BEAT a Digital Services Tax?

Patrick Driessen argues that the similarity between the U.S. base erosion and antiabuse tax and digital services taxes undermines the United States’ criticism of DSTs.

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European Union Year in Review: A Grab Bag of Decisions

Lee A. Sheppard explains important 2024 tax developments in the European Union, including key tax decisions in the EU’s Court of Justice.

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