2026

A U.S. court administratively closed a lawsuit filed by a Texas-based Sabre GLGL claiming that British Airways refused to compensate it for the U.K.’s digital services tax. The DST requires payment of 2% on “the revenues of search engines, social media services, and online marketplaces which derive value from U.K. users.” Whether British airways was required to reimburse Sabre  depends on whether DST applies to Sabre’s services under U.K. law, which the judge believed is best determined in a U.K. forum. A  resolution of these issues has significant implications for how a digital services tax is treated under U.K. law and may provide guidance to how similar tax provisions will be treated.

To read the full article, click here.

G7 anticipates an OECD report by the end of 2026 on counties’ progress on identifying common challenges linked to taxing the digital economy. Separately, G7 ministers issued a declaration reinforcing actions to promote domestic resource mobilization and public financial management in partner countries.

To read the full article, click here.

To read the full communiqué, click here.

Herzfeld describes the recent phenomenon of companies are looking to bring their operations back to the U.S., as well as various challenges companies may face in their attempt to domesticate in the U.S.

To read the full article, click here.

In the second installment of a four-part series, Gribinski explains the shortcomings of reforms targeting the digital economy when applied to autonomous artificial intelligence.

To read article, click here.

A year into the Trump administration’s global tariff campaign, many companies are still struggling to coordinate their trade functions with their tax and transfer pricing teams, risking messy audits in the years to come.

The article reports on Turkey’s proposed tax package to attract foreign investment, regional operations hubs, exporters, and high-net-worth immigrants. The proposal would provide major corporate tax exemptions for qualified service centers, reduced tax rates for export income, a long-term foreign-source income exemption for qualifying new residents, and an amnesty for funds transferred into Turkish financial institutions.  

To read the full article, click here (subscription required).

The article examines European and business concerns over California A.B. 1790, which would phase out the water’s-edge election and require worldwide combined reporting for multinational corporations doing business in California. Mandatory worldwide combined reporting could lead to double taxation, increased compliance burdens, and foreign government objections by applying California’s formulary apportionment system to global corporate income.  

To read the full article, click here (subscription required).

The article reports that Portugal plans to propose a windfall tax on energy companies that have benefited from higher prices linked to the Iran war. The proposal builds on Portugal’s 2022 excess profits tax and follows unsuccessful efforts by Portugal and other EU countries to push the European Commission toward an EU-wide energy-sector windfall tax. The article shows how governments are reviving excess profits taxation as a national fiscal response to geopolitical shocks, energy price volatility, and public pressure over corporate gains during crises.

To read the full article, click here (subscription required).

The article reports that Switzerland is considering delaying the application of OECD Pillar 2 guidance on deferred tax assets from tax years beginning in 2024 to tax years beginning in 2025. The guidance affects how preexisting deferred tax assets tied to government arrangements or new corporate tax regimes are treated in effective tax rate calculations under the GloBE rules and Switzerland’s qualified domestic minimum top-up tax.

To read the full article, click here (subscription required).

The article examines how FIRPTA’s treatment of intangible rights remains unclear for transportation infrastructure projects, even as foreign investment in AI-related data centers and supporting infrastructure becomes increasingly important. Yu argues that while recent FIRPTA reforms and REIT structures provide clearer treatment for data center investment, foreign investors in public-private transportation concessions still face uncertainty over whether operational permits, licenses, and tolling rights constitute U.S. real property interests.  

To read the full article, click here (subscription required).