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Tax Planning Organization for Economic Co-operation and Development International Tax Issues

Morgan Lewis

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

Morgan Lewis on

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

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

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

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

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 City® - 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 City® 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)

Miller Nash LLP on

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

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

A&O Shearman

OECD Pillars, the digital economy and minimum taxes

A&O Shearman on

To date, 132 jurisdictions have committed to the OECD’s two-pillar plan to reform international tax rules, as set out in its statement of 1 July 2021. Although the genesis of the proposed reforms relates to the taxation of...more

Proskauer - Tax Talks

130 countries join the OECD’s framework for international tax reform

Proskauer - Tax Talks on

Significant progress has been made in the efforts of the OECD to reach international consensus on the BEPS 2.0 proposals. Broadly, the proposals are aimed at addressing challenges relating to taxation of the modern digital...more

Proskauer Rose LLP

UK Tax Round Up - April 2021

Proskauer Rose LLP on

UK Case Law Developments - Tax avoidance motive did not prevent availability of share for share exchange treatment - In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...more

McDermott Will & Schulte

[Webinar] Tax in the City®: San Francisco - May 18th, 1:00 pm - 2:30 pm PDT

Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting. Our...more

Proskauer - Tax Talks

Comparison of the Biden Administration and Senate Finance Committee International Tax Proposals

Proskauer - Tax Talks on

On March 31, 2021, the Biden administration released a factsheet for the “Made in America Tax Plan”. On April 5, 2021, Senate Finance Chair Ron Wyden (D-Ore.) and Senators Sherrod Brown (D-Ohio) and Mark Warner (D-Va.)...more

Proskauer Rose LLP

UK Tax Round Up - February 2021

Proskauer Rose LLP on

UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

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