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G20 Leaders Summarize Key Meeting on OECD’s Two-Pillar Solution
The G20 issued a summary of the February 26-27 meeting of finance ministers and central bank governors regarding the progress of implementing provisions within the OECD's two-pillar global tax reform solution, expressing support for international tax policy cooperation within the parameters of member jurisdictions' autonomy and compliance with the OECD's standards and voicing concern over developing countries' difficulty in benefiting from international tax changes.
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When It Comes to Tariffs, Trump Can’t Have It All
The president has promised big results, from raising revenue to reviving domestic manufacturing. But many of his goals undermine one another.
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The U.N. Tax Convention Eyes Dispute Resolution
Nana Ama Sarfo explains how dispute avoidance and resolution has consistently played a role in discussions involving the U.N.'s framework convention on international tax cooperation
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OECD Working Paper Recommends Targeted Capital Gains Tax Relief
OECD countries should offer targeted capital gains tax relief instead of broad relief in order to decrease tax avoidance opportunities and discourage asset holding to delay tax payment, according to an OECD working paper.
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Lesson Plan: Analyzing Trump’s Approach to Tariffs
President Trump has been pushing tariffs in the first weeks of his new term. What are tariffs? How do they work? Are they good policy? We explore these questions, and others, in this lesson.
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Trump Plans Another 10% Tariff on Products From China
The U.S. next week will impose an additional 10% tariff on imports from China over its role in the fentanyl trade, the president said.
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White House Memo Promises Action Against Foreign Taxes
The Trump administration will respond to discriminatory taxes by foreign governments by imposing tariffs “and taking such other responsive actions necessary to mitigate the harm to the United States and to repair any resulting imbalance,” the White House said in a February 21 memo.
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Earnings Calls Are Disappointingly Quiet on Pillar 2
Martin A. Sullivan examines transcripts of multinationals’ earnings calls and SEC filings to update previous reports on how large corporations discuss the potential effects of pillar 2.
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Trump Issues Directive Aimed at Foreign Digital Services Taxes
President Trump formally requested that administration officials examine whether to impose tariffs on countries that charge digital services taxes on American companies.
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Let’s Note Overthink This: Recharacterization Under the OECD Guidelines
Michael McDonald provides context for the base erosion and profit-shifting 1.0 initiative regarding recharacterization and evaluates whether its objectives have been met.
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Consolidated Report on Amount B
The OECD has published a document that consolidates the report on the amount B transfer pricing simplification approach with related materials released throughout 2024, including a model competent authority agreement.
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Businesses Are Betting on a Tax Cut Extension
The federal budget debate has big implications for the economy. Despite questions about the math, investors expect an extensions of the 2017 tax cuts.
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Reciprocal Tariffs: Making Sense of Trump’s Hang-Up With VAT
Robert Goulder comments on the Trump administration’s push for reciprocal tariffs.
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Transfer Pricing and Tariffs: Finding Certainty in Trade Uncertainty
Allen S. Braddock examines the history of tariffs and how transfer pricing may be used to mitigate their effects.
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What Is an Applicable Corporation Under the Corporate AMT?
Kimberly S. Blanchard explains why section 59(k) and the proposed regulations are unclear and suggests an alternative, straightforward approach to the rules for foreign-parented multinational groups.
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Trump Weighs Tariffs to Counteract Foreign Taxes on Tech Firms
An executive memo takes aim at a major technology industry concern.
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Trump Floats 25% Tariffs on Autos, Chip and Pharmaceuticals
The president provided further details about his expected tariff moves.
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How Trump’s Tariffs Could Reorder Asia Trade and Exclude the U.S.
Asian countries are among the most vulnerable to President Trump’s economic grievances. But they are also best placed to make deals to minimize their exposure.
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Donald Trump considers tariffs to counter digital services taxes on Big Tech
Donald Trump is considering tariffs on countries that levy digital services taxes against American companies and tightening rules on Chinese investment in the US as he widens the scope of his global trade war.
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Trump’s Growing Focus on Tariff Revenue Raises Trade War Odds
President Donald Trump and his economic team are increasingly focusing on the revenues his tariffs would generate as he seeks to get tax cuts through Congress, pointing to an ominous path ahead for countries trying to avoid a trade war.
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Reports of Pillar 2’s Death Are Greatly Exaggerated
Adam Kern examines President Trump’s executive memorandum on the global tax deal, arguing that it will have a limited effect on the stability of pillar 2 because the United States maintains the global intangible low-taxed income structure and the strategic dynamics that support pillar 2 thus remain largely intact.
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IRS’s Periodic Adjustment Shift May Cause International Friction
Ryan Finley explains why the IRS’s new approach to periodic adjustments will likely bring the United States into greater conflict with its treaty partners.
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OECD Seeks Comment on Global Minimum Tax Return Validation Rules
The OECD is soliciting feedback from the business community on an additional set of “validation rules” that will accompany the global minimum tax return.
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EU to Consider Factoring Global Trends in Decluttering Agenda
The EU Council’s Polish presidency will ask member states whether to include international tax developments in their draft conclusions on a “future-proof tax policy which contributes to the competitiveness of the EU.”
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Trump, Harley-Davidson, and the EU: A Tale of Tariff-Skipping Gone Wrong
Robert Goulder comments on the recent tariff-skipping decision in Harley-Davidson v. Commission.
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Sovereignty, Sins, and the Reassertion of Primary Taxing Rights by the United States
Michael J. Graetz argues that the United States must reassert its primary taxing rights over income long conceded to other countries, especially income from intellectual property created in the United States, and he explains some changes necessary to make that happen.
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EU Commission Answers Questions on U.S. Tariff Policy
The European Commission released a Q&A document regarding the United States' reciprocal tariff policy, including guidance on VAT in relation to tariffs; the EU's trade surplus rules; average tariff rates on both EU and U.S. imports; and asymmetrical tariff structures.
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Canadian Firms Push for Corporate Tax Changes Amid Tariff Fight
Business groups are calling on Canada to cut or reform taxes to ease the potential economic hit stemming from the Trump administration’s tariff threats.
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Minister Asks EU to Judge Global Tax Fitness After US Rebuke
Hungary’s finance minister proposed that the EU investigate whether the minimum tax can preserve or strengthen the competitiveness of the bloc following the US’ rejection of the global tax deal.
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Will Trillions in Tariff Revenue Materialize?
Martin A. Sullivan examines available data to provide insight on the economic effects of potential tariffs on U.S. imports, and he categorizes the strategies companies have considered for mitigating the burden of tariffs.
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Will Republican Tariffs Pave the Way for a U.S. VAT?
Mindy Herzfeld examines the potential impact of President Trump’s recently announced tariffs and offers alternatives that could be less disruptive to the U.S. economy.
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Countries Ready for U.N. Tax Talks Despite U.S. Exit
Countries worldwide appear optimistic about participating in negotiations for a U.N. framework convention on international tax cooperation, despite the United States’ swift exit from the talks in early February.
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Autonomous AI and the Single Virtual Jurisdiction
Lucas de Lima Carvalho explains his proposal for a single virtual jurisdiction in the development of the taxation of artificial intelligence.
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European Commission Issues Statement on U.S. Tariff Policy
The European Commission has issued a statement regarding the announced U.S. tariff policy, saying it would have negative economic effects and promising that "the EU will react firmly and immediately against unjustified barriers to free and fair trade."
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BIAC Responds to PCT Tax Incentives Principles Consultation
Business at OECD issued a letter responding to the Platform for Collaboration on Tax's (PCT) public consultation on its guidance for tax incentives principles for international policy purposes and introducing the OECD's global minimum tax standard, urging the PCT to lighten restrictions regarding tax incentive definitions and jurisdictional autonomy as well as provide explicitly clear pillar 2 guidance.
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Trump's Plan to Exit OECD Deal Threatens Two Canada Tax Rules
The future of Canada’s digital services tax and proposed undertaxed profits/payments rule—and possibly its approach to Pillar Two and international tax more broadly—is precarious in the face of international trade pressures and the Trump administration’s threats about the OECD’s global tax deal.
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EU Official Reiterates Commitment to OECD Global Tax Deal
The European Union remains committed to implementing the global tax deal despite the US backtracking, the EU’s top economic official said Tuesday.
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Why Trump Tariff Push Is Targeting Value-Added Taxes: Explained
President Donald Trump doesn’t like other countries’ value-added taxes. Trump said Thursday that his administration would look at imposing “reciprocal” tariffs against other nations. They would be aimed at offsetting not only the tariffs those countries charge on US goods, but also other regulatory and tax measures that Trump regards as unfair to the US—including VATs, which many countries impose on the sale of goods and services.
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What is Donald Trump’s ‘reciprocal’ tariff plan?
Donald Trump has unveiled an overhaul of the US’s trading relationship with many of its partners and allies, launching what he dubs a “fair and reciprocal plan” for trade.
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Trump’s Reciprocal Tariff Plan Targets European VAT
President Trump has ordered advisers to craft new tariffs for countries that have a trade deficit with the United States by calculating all costs related to trade barriers and subsidies provided to domestic corporations.
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Should Country-by-Country Reporting Be Public?
Reuven S. Avi-Yonah explains why concerns about the risks associated with publicly disclosing country-by-country reports are exaggerated and that the benefits outweigh the costs.
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Trump Moves to Impose Reciprocal Tariffs as Soon as April
President Donald Trump ordered his administration to consider imposing reciprocal tariffs on numerous trading partners, raising the prospect of a wider campaign against a global system he complains is tilted against the US.
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Trump says EU’s value added tax will be viewed by US ‘as a tariff’
Donald Trump repeatedly attacked the EU over tariffs, taxes, regulations and a legal system that he said was unfair to US companies.
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EU Commission Goes Back to Drawing Board on Interest, Royalties
The European Commission has announced the withdrawal of its proposal to revise the interest and royalty directive, which was made partially obsolete by pillar 2, and is now looking at aligning EU antiabuse clauses.
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Opinion: ‘Reciprocal’ Tariffs Make No Sense
How is it in America’s national interest to let other countries decide what duties we pay?
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Where is Trump’s Tariff Strategy Going?
A state-of-play on the president’s tariffs so far and what might be in store.
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Trump Says He’ll work Global Trading Relations With “Reciprocal’ Tariffs
The president said his advisers would devise new tariff levels reflecting countries’ tariffs, taxes, subsidies and other policies affecting trade with the United States.
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IRS Memo Marks a Major Shift in Transfer Pricing Approach
Ryan Finley explains why the IRS’s recent advice memorandum on periodic adjustments may signal a significant change in transfer pricing enforcement approach.
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EU Is Attempting to Sidestep U.S. Steel Tariff Snares
EU lawmakers have denounced the weaponization of economic policy by the new U.S. administration, and the European Commission has promised a firm response to President Trump’s announced tariffs on EU steel.
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Pillar 2 in the Age of Conquest
Robert Goulder comments on President Trump’s executive order addressing extraterritorial taxation.