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Supreme Court May Opt for Narrow Ruling on Foreign Earnings Tax

  • By Aysha Bagchi
  • By Samantha Handler

The US Supreme Court will hear a case that could upend wide sections of US tax law, but experts say the justices may ultimately coalesce around a narrower ruling. If the court strikes down the foreign earnings tax, it could jeopardize other taxes tied to multinational arrangements.

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UK Treasury Agrees to Review Digital Tax Contingency Plans

  • By Danish Mehboob

The UK Treasury agreed to review and provide progress reports on the global tax agreement and its digital services tax and provide a contingency plan in case the UK DST needs to be extended past 2025.

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Global Tax Deal Can Help Declutter National Rules, OECD Says

  • By Danish Mehboob

An OECD official said countries should review and slim down national rules that may no longer be needed now that there is a global minimum tax approach.

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Siemens Global Tax Head Criticizes OECD Global Deal Rollout

  • By Danish Mehboob

The global head of tax at Siemens said that businesses have not had a proper chance to provide their opinions on the global tax deal, which he described as an anti-democratic process..

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Germany to Start Legislating for OECD Global Minimum Tax

  • By Stephanie Soong

After consulting on transporting an EU directive implementing global minimum tax rules under pillar 2 of the OECD’s two-pillar global tax reform plan, Germany is ready to take the next step, a German official said.

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EU Wants SAFE Proposal to Focus on 'Bad Apples,' MEP Says

  • By Sarah Paez

A European Commission proposal to penalize intermediaries that facilitate tax avoidance and aggressive tax planning aims to target “bad apples,” not law-abiding tax advisers, Dutch member of the European Parliament Paul Tang said.

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Pillar 2 Could Raise Taxes on Multinationals in U.S., CRS Says

  • By Congressional Research Service

The pillar 2 proposed global minimum tax could raise taxes on multinationals’ operations in the United States even if the country fails to act on the proposal, and it could reduce the benefit of credits or other domestic tax incentives, the Congressional Research Service said in a June 29 report.

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Pillar 2 Concerns Persist Amid Australia's Draft Intangibles Rule

  • By Stephanie Soong

Australia’s amended draft rule denying deductions for intangibles payments linked to low-tax jurisdictions reflects some stakeholder concerns, but its interaction with OECD global minimum tax rules remains to be seen, practitioners said.

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Minimum Tax May Spur Rethink of Incentives, OECD Official Says

  • By Sarah Paez

A global minimum effective tax rate will likely encourage governments to stop offering tax incentives that reduce a multinational enterprise’s profit and design incentives to cost-effectively stimulate investment, according to an OECD official.

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Supreme Court to Hear Transition Tax Case With Vast Implications

  • By Andrew Velarde

In Moore v. United States, the Supreme Court has decided to take up a constitutional challenge to the validity of the transition tax in the face of 16th Amendment concerns, and the fallout from a taxpayer-favorable decision could be monumental.

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Spain Aims for EU Deal on Beneficial Ownership Criterion

  • By Elodie Lamer

The Spanish presidency of the EU Council, which begins in July, will try to get member states to agree on proposals to strengthen the EU list of noncooperative jurisdictions for tax purposes.

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Could Bilateral Investment Treaties Kill Pillar 2?

  • By Mindy Herzfeld

Mindy Herzfeld considers how commitments countries have made under bilateral investment treaties might hinder adoption of the pillar 2 global minimum tax.

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U.N. Revisits the International Tax Architecture

  • By Nana Ama Sarfo

Nana Ama Sarfo discusses a recent U.N. policy brief outlining ways to improve the international tax system for the benefit of developing countries.

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Kenyan Parliament Approves Cryptoasset, Digital Creator Taxes

  • By Sarah Paez

The Kenyan National Assembly has passed a controversial finance bill that will introduce a withholding tax on income of digital content creators and a tax on cryptoassets.

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OECD Removes Three Countries From Its Harmful Tax Practices List

  • By Danish Mehboob

The OECD removed San Marino, Aruba, and Jordan from its harmful tax practices list after they amended their incentive regimes to address concerns raised by the organization.

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France’s Macron Champions Global Taxation for Poverty, Climate

  • By William Horobin

French President Emmanuel Macron called for global taxation to finance the fight against poverty and climate change. He proposed new taxes on airline tickets, financial transactions, and shipping.

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Chile-U.S. Tax Treaty Gets Senate Approval, Heads to White House

  • By Cady Stanton

The Senate voted 95 to 2 to approve a tax treaty between the United States and Chile after more than a decade of delay.

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U.S. Tax Revenue Would Decrease Under OECD Pillar 2, JCT Says

  • By Cady Stanton

Enacting the OECD’s pillar 2 global minimum tax is estimated to result in a decrease of federal tax receipts for the United States over the next ten years, according to a new analysis.

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European Commission Avoids Political Headaches With FASTER

  • By Elodie Lamer

The European Commission has published its withholding tax reform proposal, insisting that it is strictly procedural, as it tries to gain quick approval of the plan, unlike its previous pro-business proposals.

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U.K. Will Keep DST Until Pillar 1 Rules Are in Place

  • By Sarah Paez

The United Kingdom will maintain its digital services tax until pillar 1 of the two-pillar plan to reform global corporate tax rules is implemented, according to Paul Tang, a Dutch member of the European Parliament.

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The UTPR and the Credits

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah examines the intersection between the UTPR and tax credits recently enacted by the Inflation Reduction Act and the CHIPS Act.

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National Horsemen's and the Constitutionality of the Corporate AMT

  • By Mindy Herzfeld

Mindy Herzfeld considers the implications of the Fifth Circuit’s holding in a recent nondelegation doctrine decision for the constitutional validity of the corporate alternative minimum tax.

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Countries Mull U.S. Call for Extending Digital Tax Moratorium

  • By Stephanie Soong

The United States has proposed extending a digital services tax moratorium under the OECD’s pillar 1 framework, and while some countries are open to the idea, others are keeping their cards close to their chests.

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United Kingdom Seeks Input on Pillar 2 Draft Guidance

  • By Sarah Paez

The United Kingdom is seeking public input on draft guidance on the administration, chargeability, and scope of the taxes introduced by the country’s pillar 2 legislation.

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World's Biggest Offshore Center Backs Effort to Fight Corporate-Tax Avoidance

  • By Paul Hannon

Swiss voters overwhelmingly supported a global move to establish a minimum tax on corporate profits, with the world’s largest offshore center feeling the pressure to help crack down on tax avoidance by the biggest international companies.

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New Jersey Lawmakers Launch Action on Corporate Tax Changes

  • By Michael J. Bologna

New Jersey's SB 3737 would enlarge the state's GILTI exclusion from 50% to 95%, in line with neighboring states. The change could cost the state $122.8 million per year, but supporters maintain it would make New Jersey more competitive.

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GOP Plan Would Let Companies Opt Out of Foreign Tax Credit Rules

  • By Michael Rapoport

A new tax proposal from House Republicans would allow companies to temporarily disregard stricter standards for taking advantage of the foreign tax credit. GOP lawmakers argue the proposal would shorten US companies' supply chains, boost their competitiveness, and prevent double taxation.

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Developing Nations Need UN to Air Their Tax Issues, Official Says

  • By Michael Rapoport

Developing countries want a UN forum to discuss global tax cooperation because they feel the OECD hasn't addressed their concerns. The UN secretary general is working on a report that could lead to the creation of an intergovernmental tax-cooperation body.

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Taiwan Trade Bill Clears House Panel in United Vote

  • By Chris Cioffi

The House Ways and Means Committee unanimously approved a bill to approve a trade pact with Taiwan. The bill could lead to a tax agreement between the two countries to eliminate double taxation and promote investment.

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European Court of Justice Issues Advocate General Ruling on Luxembourgish State Aid to Amazon


The European Court of Justice's advocate general sided with the General Court in its decision to overturn the European Commission's ruling that Amazon received illegal state aid from Luxembourg. The advocate general found that the Commission incorrectly applied the arm's length principle and failed to identify the framework for normal taxation in Luxembourg.

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Boost Social Economy Through Tax Policy, European Commission Says

  • By Stephen Gardner

The European Commission recommends that EU countries review their tax systems to encourage social economy enterprises, which prioritize community or environmental causes. The Commission suggests offering tax breaks for donations and retained profits and reducing the tax compliance burden.

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More Than 250 Delegates Join First OECD Global Tax Deal Seminar

  • By Danish Mehboob

The OECD held an information sharing meeting to help developing countries implement the global minimum tax rules. The meeting brought together early movers on the deal to discuss change management and the necessary steps to implement a minimum tax.

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Multinationals Should Beware New European Tax Rules on Horizon

  • By Bill Henson

ATAD 3 is a pending EU tax rule intended to crack down on the misuse of EU holding companies. The rule will take effect as early as 2024, and companies that are out of compliance could face penalties.

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UK Tax Office Clarifies How Minimum Tax Regime Will Hit Business

  • By Danish Mehboob

The UK tax office released a draft proposal for how it will implement its version of the global minimum tax framework. The proposal includes details on which groups and entities will be subject to the minimum tax, as well as how the tax will be administered.

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Bill Overhauling Brazil’s Transfer Pricing Rules Signed Into Law

  • By Isabel Gottlieb

Brazil adopted new transfer pricing rules in line with global norms, which will make it more likely that US multinationals operating there will be able to receive foreign tax credits. The rules become mandatory in 2024, but companies can choose to apply them in 2023.

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Global Tax Mess Awaits U.S. Companies, and Congress Isn't Helping

  • By Richard Rubin

U.S.-based multinational companies will start paying higher taxes in foreign countries next year under a global minimum-tax agreement. The following year, the deal will cause U.S. companies to lose domestic tax breaks. In 2026, U.S. taxes on companies’ foreign income will rise because of long-delayed provisions of the 2017 tax law. Despite U.S. officials negotiating in 2021 for a way to limit corporate tax avoidance, Congress is deadlocked over what to do and this will ignite consequences for American companies.

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Big Companies on Verge of New Market for Clean-Energy Tax Credits

  • By Richard Rubin

The Biden administration is setting the stage for large companies to start buying clean-energy tax credits, kick-starting a new market at the core of last year’s climate law.

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'Cautious Optimism' on Pillar 1 Tax Deal, Nembhard Parker Says

  • By Stephanie Soong

The inclusive framework on base erosion and profit shifting is staying positive about finalizing a multilateral convention to implement part of the OECD’s two-pillar global tax plan, but challenging discussions remain, the group’s co-chair said.

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Mexico Offers Tax Free Investments to Boost Southeast

  • By Sam Edwards

The Mexican government is offering tax breaks to companies that invest in 10 new development zones in the southeast of the country. The tax breaks include a three-year exemption from corporate income tax with a 50% reduction for an additional three years.

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Treasury Plans More Guidance on Intellectual Property Transfers

  • By Michael Rapoport

The Treasury Department plans to release additional guidance on transfers of intellectual property into and out of the United States. The guidance will address questions that were not addressed in proposed rules issued in May.

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EU Wealth Tax Debate Heats Up As Governments Search for Revenue

  • By Stephen Gardner

Some EU policymakers believe wealth taxes could provide new sources of revenue, while others argue they would be difficult to implement and enforce. Supporters claim skepticism about wealth taxes is due to shortcomings of the few currently in place and have proposed fixes.

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Taiwan Trade Bill Unveiled, Could Pave Way to Tax Pact

  • By Chris Cioffi

Approval of a trade pact with Taiwan has laid the foundation for a tax deal between the two countries, according to House and Senate tax writers. Taiwan is not recognized by the US as a sovereign nation, so it can’t sign treaties, but lawmakers believe significant treaty-like benefits could be provided through the tax code.

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Carried Interest Tax Advantage Faces Legal Challenge in United Kingdom

  • By Danish Mehboob

A nonprofit law firm and a UK businessman have filed a legal challenge against the UK tax authority, arguing that private equity managers should be taxed at a higher rate. The challenge seeks to end the practice of taxing carried interest as a capital gain at 28% instead of income at above a 40% rate.

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Proposed Regs Terminate Application of Section 367(d), Part II

  • By Carrie Brandon Elliot

Carrie Brandon Elliot reviews the new proposed regs in reg. section 1.367(d)-1(f) that allow the termination of contingent payments under section 367(d) when intangible property is repatriated.

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A New Blueprint for Africa: The Case for QDMTTs

  • By Nana Ama Sarfo

Nana Ama Sarfo describes the African Tax Administration Forum's suggested approach to QDMTTs and their potential importance for African countries.

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Time to Declutter Tax Systems Amid Pillar 2 Adoption, Pross Says

  • By Stephanie Soong

As countries implement global minimum tax rules, it might be time to consider changing or eliminating potentially duplicative anti-tax-avoidance measures, like controlled foreign corporation rules, an OECD deputy tax chief said.

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U.S., U.K. to Seek Energy Subsidy Agreement

  • By Alexander Rifaat

President Biden and British Prime Minister Rishi Sunak announced plans to reach a deal on critical minerals that will allow U.K. auto manufacturers to at least partially qualify for the clean vehicle tax credit included in the Inflation Reduction Act.

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Comments Requested on Services FTC Licensing Exception

  • By Michael Smith

Speaking on June 7 at a Texas Federal Tax Institute conference, Tracy Villecco of the IRS Office of Associate Chief Counsel (International) said the government is open to hearing comments on a fact pattern “where the withholding payment on a service payment is in respect to services performed within that source jurisdiction, similar to the single-country exception for royalties.”

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OECD Countries Want to Aid Wider Adoption of CbC Reporting

  • By Sarah Paez

Leaders from OECD member countries pledged to help developing countries implement the two-pillar plan to modernize corporate tax rules while calling on the OECD to aid those countries in introducing country-by-country reporting rules.

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Norway Consults on Pillar 2 Proposal

  • By Sarah Paez

The Norwegian Ministry of Finance has presented for consultation a proposal that would implement global minimum tax rules in line with pillar 2 of the OECD’s two-pillar plan to modernize corporate tax rules.

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