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Double Taxation Organization for Economic Co-operation and Development Tax Liability

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Ius Laboris

Telework from abroad: tax consequences for employers?

Ius Laboris on

As employers face growing calls to allow employees to ‘work from anywhere’, they should also consider the possible tax consequences of inadvertently creating a permanent establishment in another country. But what counts as...more

Cadwalader, Wickersham & Taft LLP

Burlington Loan Management DAC: Treaty Shopping Provisions Did Not Apply

The UK’s First-tier Tribunal recently held that the payment of interest received by Burlington Loan Management DAC (“BLM”) (an Irish tax resident company) was not to be denied the benefits of the relief afforded under the...more

Jones Day

The UK’s Digital Services Tax: Where Are We Now?

Jones Day on

Current Status: The UK Government is moving ahead with its implementation of the Digital Services Tax ("DST") despite concerns raised by the United States and the Organisation of Economic Co-operation and Development ("OECD")...more

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