2023

Ryan Finley explains why, despite Medtronic’s claims to the contrary, the section 482 regulations do not swallow their own comparability methodological reliability standards.

Germany’s government is preparing a legislative proposal to tax online platforms like Google and Facebook to counter what the country’s culture minister described as “clever . . . tax avoidance.”

A new European Commission proposal wants to harmonize several aspects of employee taxation across borders for start-ups and businesses scaling up to encourage innovation.

Provision could hike taxes on some foreign companies’ U.S. investments and reduce the appetite for U.S. assets.

The American Chamber of Commerce to the European Union has written to EU Tax Commissioner Wopke Hoekstra saying that uncertainties regarding the EU’s pillar 2 directive and its interaction with the U.S. tax system must be resolved quickly.

EU member states are ready to negotiate simplification of the carbon border adjustment mechanism with the European Parliament after tightening the regulation’s antiabuse measures.

European Parliament rapporteur Evelyn Regner said the definition of a permanent establishment in the proposed Business in Europe: Framework for Income Taxation system should include companies that have a significant economic — if not physical — presence.

Parthasarathi Shome explores the ramifications of the recent expanded use of tariffs by the United States.

The OECD has released several new and updated transfer pricing country profiles containing information about their positions on the optional amount B simplified and streamlined approach to pricing baseline and marketing distribution transactions.

Robert Goulder comments on the recently announced United Kingdom-United States trade deal framework.

Wade Sutton proposes updating U.S. dual consolidated loss rules to reflect the post-2017 international taxation environment.

The New Zealand government has pulled back proposed legislation that would have implemented a digital services tax, citing countries’ support of OECD work to address the tax challenges of the digital economy.

The tax committee of a U.S. business group told Treasury’s top OECD negotiator that it supports the government’s push to ensure that the U.S. tax system exists separately from the OECD's pillar 2 regime.

Australia’s Productivity Commission, which advises the government on economic policies, has asked for recommendations on reforming the country’s corporate tax regime and reducing regulations.

An international governance platform for tax has released a final report on its principles to guide policymakers in designing tax incentives to avoid economic distortion and revenue loss.

The Platform for Collaboration on Tax published a report May 20 providing guidance to international policymakers on designing and developing tax incentives in ways that avoid cross-border issues and revenue losses.

Michael J. Waggoner proposes replacing the lowest brackets of income tax with a VAT as an alternative to tariffs.

Mindy Herzfeld examines U.S. international tax policy’s shift toward unilateralism under the Trump administration.

Addressing U.S. concerns about pillar 2 and stabilizing the global minimum tax are OECD member countries’ first priorities, and a return to discussions on pillar 1 “will come after,” a top OECD official said.

Hong Kong’s legislative council is moving forward with a proposal to use its existing general antiavoidance rule to address arrangements that can potentially exploit Hong Kong’s pillar 2 minimum tax rules.

Miguel Cortez Pimentel and Joana Sobral examine the practicalities of the European Council directive on faster and safer relief of excess withholding taxes (FASTER).

German state finance ministers have asked the federal government to ensure that the global minimum tax rules under pillar 2 of the OECD’s two-pillar tax reform plan won’t leave German companies at a competitive disadvantage.

Poonam Khaira Sidhu examines the potential effects of the United States’ lack of participation with pillar 2.

The latest section of House Republicans’ reconciliation tax bill revives proposals to allow the United States to retaliate against what Republicans call discriminatory extraterritorial taxes, this time explicitly referencing digital services taxes and undertaxed profits rules.

The European Commission said it will work to avoid a fragmented situation on pillar 2 that would lead to a “bureaucratic nightmare” for European companies.

Muhammad Ashfaq Ahmed examines the title change of the U.N. Model Double Taxation Convention Between Developed and Developing Countries to the U.N. Model Tax Convention.

The OECD has released an updated consolidated commentary to the global anti-base-erosion model rules under pillar 2 of its two-pillar global tax reform plan, incorporating three years’ worth of administrative guidance.

Katherin Díaz Velilla explains the OECD’s and U.N.’s approaches to creating an international tax framework and shows how developing nations and Latin American countries will play an important role in the U.N. approach.

Treating the global intangible low-taxed income regime as an income inclusion rule and extending the transitional undertaxed profits rule safe harbor won’t be sufficient to address U.S. concerns about pillar 2, a Treasury official said.

A former Treasury official expressed hope that the Trump administration’s tariffs, though ill-advised, could spur policymakers to give more credence to the merits of a consumption-based tax in the United States.

 The government has formed a working group to clarify application of a long-dormant antiabuse statute to a check-the-box election, according to a Treasury official.

Reuven S. Avi-Yonah and Doron Narotzki examine how the history of the United States’ relationship with the global economy could offer insight into innovative tax options in the current economic environment.

Carrie Brandon Elliot interviews four tax professionals to discuss the status of amount B in their respective jurisdictions and compliance suggestions for taxpayers.

R. Glenn Hubbard examines a GOP tax bill that could curb the fears of President Trump's tariffs with a pro-growth tax policy that advances the Made in America agenda. 

While statutory tax rates in the EU declined only slightly in 2014-2022, countries increasingly relied on base-narrowing measures, a trend that will require reconsideration of tax incentives under pillar 2, the EU Tax Observatory warned.

Proposed amendments to a draft report on the role of simplification in EU competitiveness swing between preserving the OECD tax agreement and safeguarding the EU directive.

The Kenyan government is aiming to expand the scope of its significant economic presence tax to tackle the digital economy despite ongoing negotiations on OECD pillar 1 tax reforms, practitioners said.

Mindy Herzfeld examines tax options that could raise sufficient revenue to rescue the United States from its deficit

Lucas de Lima Carvalho explains the legal and policy motives behind Brazil’s digital "detox" tax and considers whether the tax is the right tool for the job.

In a letter to the editor, Jefferson VanderWolk asks whether it’s time to reconsider the global minimum tax.

Robert Goulder comments on the U.S. trade representative’s 2025 National Trade Estimate Report.

EU member states are brainstorming ideas for new own resources for the EU budget, including external border taxes and regulations such as the undertaxed profits rule under the OECD's pillar 2 global minimum tax framework.

Allison Christians provides a history of tariffs in the United States, explaining how both extremes of protectionism and liberalization have affected trade and the economy overall.

The EU tax community generally believes that options laid out by the EU Council’s Polish presidency to allay U.S. concerns about the OECD's pillar 2 minimum tax rules could be used in tandem.

Mindy Herzfeld examines the history of the base erosion and antiabuse tax and considers options for its future.

Błażej Kuźniacki examines the interplay between taxation and international law by considering possible U.S. defense measures against the UTPR (formerly known as the undertaxed payments rule) and digital services taxes.

The U.N. tax convention negotiations should build on what was achieved in the OECD two-pillar plan discussions and implementation, according to South Africa's finance minister.

The EU Council’s Polish presidency reportedly has proposed three options to assuage U.S. concerns about the OECD's pillar 2 minimum tax rules.

Reuven S. Avi-Yonah examines the history of IRS transfer pricing enforcement to provide context for the Coca-Cola litigation.

Developing countries should adopt taxes aimed at the digital economy, including digital services taxes, and band together to resist external threats against those measures, the South Centre told G24 nations.