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Tax Planning Organization for Economic Co-operation and Development

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

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Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

Walkers

Overview of the Cayman Islands Economic Substance requirements

Walkers on

Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more

Goodwin

Pillar II in Luxembourg: What Investment Funds Need to Know

Goodwin on

The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more

Katten Muchin Rosenman LLP

Will Pillar Two Crumble Before It's Built?

Over 135 jurisdictions signed up for a global Organisation for Economic Cooperation and Development (OECD) project in October 2021 aimed at reforming the international taxation system. A Two-Pillar approach was developed to...more

Proskauer - Tax Talks

Trump Administration Disavows the OECD Global Tax Deal

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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

Morgan Lewis

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

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The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

McDermott Will & Schulte

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

A&O Shearman

Amount B or not to be? The OECD’s Pillar One Amount B report

A&O Shearman on

The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more

Eversheds Sutherland (US) LLP

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect

With more and more countries signing on to Pillar Two, “GILTI Conscience” hosts Nate Carden and David Farhat are joined by Vikram Chand, associate professor of law at the University of Lausanne, to discuss what this means for...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing

For law students or young practitioners pursuing a career in tax law, there are numerous possibilities to gain hands on experience and knowledge. However, learning about and finding an entry into transfer pricing may be much...more

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Freeman Law

Country-by-Country Reporting

Freeman Law on

In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

Hogan Lovells

Potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK

Hogan Lovells on

In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an intra-group loan is going to be tax deductible. Following a recent case,...more

Proskauer Rose LLP

UK Tax Round Up - March 2022

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Welcome to the March edition of the Proskauer UK Tax Round Up. In his Spring Statement, the Chancellor focused on measures to alleviate the increasing cost of living and to boost investment in the economy but there were no...more

Hogan Lovells

First Spanish ruling on the existence of a PE due to teleworking during and after COVID-19 lockdown

Hogan Lovells on

The Spanish Tax Authorities ("STA") have issued the first ruling analysing the existence of a permanent establishment ("PE") in Spain due to an employee who worked from home during and after the COVID-19 lockdown. In this...more

Foodman CPAs & Advisors

CĂłmo las administraciones tributarias pueden monitorear la capacitaciĂłn en cumplimiento de FATCA y CRS de las IF

Un nuevo informe de la OrganizaciĂłn para la CooperaciĂłn y el Desarrollo EconĂłmico (OCDE) dice que las administraciones tributarias pueden evaluar el cumplimiento de FATCA y CRS de las instituciones financieras al monitorear...more

Foodman CPAs & Advisors

Preguntas que las IF deberĂ­an hacer a los Proveedores de Servicios Externos de FATCA y CRS

GuĂ­a de la OCDE ofrece a las instituciones financieras asesoramiento sobre la contrataciĂłn de organizaciones de servicios externos para gestionar el cumplimiento....more

Miller Nash LLP

Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies

Miller Nash LLP on

Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more

Freeman Law

OECD Issues Model Rules on Nexus and Sourcing

Freeman Law on

On February 4, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued model rules for nexus and revenue sourcing under Pillar One of the international tax agreement (the so-called “two-pillar...more

McDermott Will & Schulte

[Webinar] Tax in the CityÂŽ - March 1st, 11:30 am - 1:00 pm PDT

The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the CityÂŽ program of 2022, which will cover federal and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Multinationals Should Consider Adding ‘Competent Authority Processes’ to Their Tax Strategies

Takeaways - Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized. The “competent authority...more

Miller Nash LLP

When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)

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The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more

Brownstein Hyatt Farber Schreck

OECD Announces Global Tax Deal

The Organization for Economic Cooperation and Development (OECD) announced earlier today that 136 countries reached agreement on the Inclusive Framework on Base Erosion and Profit Shifting. The two-pillar framework would...more

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