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Tax Rates Organization for Economic Co-operation and Development

Cooley LLP

Treasury Department Asks Congress to Drop Proposed Legislation to Increase Tax Rates on Non-US Investors From Certain Countries

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On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

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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

Eversheds Sutherland (US) LLP

Unpacking the big beautiful international tax provisions of the One Big Beautiful Bill

On May 12, 2025, the House Committee on Ways and Means (WMC) released a draft of the tax provisions of the highly anticipated budget reconciliation bill, referred to as the “One Big Beautiful Bill” Act (OBBB), and on May 14,...more

Hogan Lovells

New Section 899 – Enforcement of remedies against unfair taxes

Hogan Lovells on

On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more

Mayer Brown

Congress Proposes a ‘Big Stick’ to Target Discriminatory Tax Measures

Mayer Brown on

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

Miller Canfield

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

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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

Walkers

Guernsey Adopts OECD's Global Minimum Tax Rate of 15%

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Guernsey has passed legislation to implement the OECD's global minimum tax rate of 15%, known as "Pillar 2", which will apply for fiscal years commencing on or after 1 January 2025....more

Walkers

Jersey Adopts OECDs Global Minimum Tax Rate of 15%

Walkers on

Jersey has passed legislation to implement the OECD's global minimum tax rate of 15%, known as "Pillar 2", which will apply for fiscal years commencing on or after 1 January 2025....more

Barnea Jaffa Lande & Co.

Tax innovations in Israel during 2024

Barnea Jaffa Lande & Co. on

Over the past year, alongside handling the economic repercussions of the war and issuing financial assistance to war victims and to evacuees, the courts, the legislative authority and the Israel Tax Authority continued their...more

Walkers

15% Global Minimum Tax Rate: Draft Legislation lodged in Jersey

Walkers on

Following Jersey's intention to implement the OECD proposals for a 15% global minimum tax rate (known as "Pillar 2") in May 2024, draft legislation has now been lodged introducing a new standalone Multinational Corporate...more

Goodwin

Proposed Amendments to Pillar Two Law in Luxembourg

Goodwin on

On 12 June 2024, Luxembourg published a bill of law amending the law of 22 December 2023 (the Pillar Two Law[1]) implementing EU directive no. 2022/2523, largely known as the “EU Minimum Tax Directive” or “Pillar Two...more

Walkers

Guernsey announces further details of OECD Pillar Two implementation

Walkers on

Following on from the Crown Dependencies re-affirming their commitment to implementing the Organisation for Economic Co-operation and Development’s Pillar Two framework for accounting periods commencing on or after 1 January...more

A&O Shearman

What does Pillar Two mean for structured finance?

A&O Shearman on

Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size. The reforms reflect the outcome of an...more

BCLP

Impact of Pillar Two on Tax Risk Apportionment for a Corporate Sale

BCLP on

How do you draft a tax covenant for a corporate sale when the Seller Group is within the scope of a Pillar Two charge? This is an issue that will become increasingly relevant as we approach the Pillar Two start date at the...more

Walkers

Jersey and Guernsey response to Pillar Two Framework on global tax rates

Walkers on

Guernsey and Jersey have today issued a joint statement with the Isle of Man on their intentions to implement the OECD global initiative to set a minimum effective tax rate for the world’s largest multinational enterprises,...more

Morrison & Foerster LLP

First Draft of German Implementation of Global Minimum Taxation Published

The German Federal Ministry of Finance circulated a first discussion draft of the implementation of the OECD-Guidelines for global minimum taxation, after the European Union therefore had published a Directive (Directive (EU)...more

A&O Shearman

OECD Pillars: Full steam ahead

A&O Shearman on

2023 is set to be a year of change for the global tax landscape. After many years of negotiation, development and consultation, implementation of the OECD’s Pillar One and Pillar Two reforms to international taxation is now...more

McDermott Will & Schulte

International Legal Highlights | June 2022

EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE - On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...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

McDermott Will & Schulte

An Overview of OECD Pillar 2

The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more

McDermott Will & Schulte

OECD Pillar 2 Q&A

WHAT IS THE AIM OF PILLAR 2 RULES? The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...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

White & Case LLP

Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy: 15% Minimum Tax for...

White & Case LLP on

On November 4, 2021, 137 countries, under the aegis of the OECD, adhered to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. Pillar 1 aims to ensure a better...more

White & Case LLP

Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy: 15% Minimum Tax for...

White & Case LLP on

On November 4, 2021, 137 countries, under the aegis of the OECD, adhered to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. Pillar 1 aims to ensure a better...more

A&O Shearman

The global minimum tax rate: Are we nearly there yet?

A&O Shearman on

On 20 December 2021, the OECD published keenly awaited model rules designed to implement Pillar Two of its ambitious plans to reform international taxation. ...more

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