GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
AI Around the Globe: What to Know in 2024
GILTI Conscience Podcast | Amount B Back in the Spotlight
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
Podcast: Digital Taxation—Implications for EU Technology Companies
Podcast: Credit Funds: Withholding Tax on European Investments
New anti-abuse provisions
FCPA Compliance Report-Episode 333, Professor Samuel Buell
FCPA Compliance Report-Episode 329, James Koukios
At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more
The Trump administration has declared that prior U.S. commitments under the OECD’s Pillar Two agreement would have no domestic effect unless approved by Congress, reflecting long-standing opposition....more
Within the first month of President Trump’s second term, the nation has witnessed several executive actions relating to tax and tax administration that affect American businesses and consumers. This article summarizes some of...more
On his first day in office, among the numerous Executive Orders (EO) released, President Donald Trump announced the America First Trade Policy EO designed to prioritize American interests in international trade and tax and,...more
Since assuming office on January 20, 2025, President Donald Trump has prioritized tax policy, issuing a series of directives aimed at boosting economic growth and advancing the “America First” agenda. On his first day in...more
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
Day one of the Trump administration and the impact of the new U.S. President and Republican-controlled House and Senate is being felt in many areas, including in the international tax sphere. On 20 January, President Trump...more
On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more
TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...more
Welcome to 2020! Although we have enjoyed the time off, we have been itching to get back into the swing of things. Since you have not seen Taxation & Representation in your inbox since the previous decade, we thought it was...more
On July 10, 2019, the US Trade Representative (USTR) initiated an investigation under Section 301 of the Trade Act of 1974 (Trade Act) with respect to France’s new Digital Services Tax (DST) Act (LOI n° 2019-759 du 24 juillet...more
United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more