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International Tax Issues Foreign Investment Organization for Economic Co-operation and Development

Holland & Knight LLP

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

Holland & Knight LLP on

In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

K&L Gates LLP on

Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

Jones Day

Dispute Resolution Under OECD’s “Pillar Two” 15% Global Minimum Tax Remains Unclear

Jones Day on

In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more

Skadden, Arps, Slate, Meagher & Flom LLP

Exploring Potential Investor-State Treaty Challenges to the OECD’s Pillar Two Model Tax Rules

Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax Law Struggles To Keep Pace With the Proliferation of Cryptocurrency

Takeaways - The technical architecture of various cryptocurrencies makes it difficult to bring them within existing tax rules, even those designed to deal more generally with the digital marketplace. The U.S., U.K. and...more

Freeman Law

International Tax Treaty: Australia

Freeman Law on

Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

White & Case LLP

Understanding Tax: EU tax challenges for cross border investing and financing

White & Case LLP on

This article is produced by our European Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the international tax environment. The last...more

Bennett Jones LLP

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

Bennett Jones LLP on

On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more

Bennett Jones LLP

New Ratifications of the OECD's Multilateral Instrument Put Canadian Resource Holding Structures at Risk

Bennett Jones LLP on

Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more

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