U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework
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The Need for Income Sourcing Changes
Jeffery M. Kadet responds to a recent article on the potential reform of income sourcing rules and emphasizes that simplicity, objectivity, and results that are fair to both taxpayers and tax authorities are key, including the need for sourcing rules to be applied on a unitary basis when appropriate and for the activities of independent contractors (especially when related) to be attributed to the taxpayer.
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