2023

The Bermudian government is asking for stakeholder input on draft legislation providing for three proposed refundable tax credits designed to be in line with OECD pillar 2 global minimum tax rules.

The OECD inclusive framework on base erosion and profit shifting on September 8 published a set of revisions to the action 5 minimum standard on the exchange of information on tax rulings, including an updated template for exchanges; recommendations for efficiently completing the template; amended terms of references applicable for the 2025-2026 fiscal year and onward; an improved peer review assessment methodology beginning in 2026; and clarifications for identifying tax practice risks and information exchange expectations.

The OECD’s proposed side-by-side alternative to the 15% global minimum tax would be a win not just for the US, but also for global tax sovereignty and certainty.

Daniel Maggacis examines the adoption of pillar 2 and contemplates whether advocating for a minimum tax rate for multinationals may unintentionally normalize 15 percent as a benchmark for an internationally acceptable company tax rate.

Kimberly S. Blanchard explores the side-by-side approach of the OECD/G20 inclusive framework and the U.S. worldwide taxation system.

Negotiators at the OECD are racing to rewrite large parts of the global minimum tax framework by year-end to placate the US, a goal that appears elusive as dozens of countries raise concerns about being put at a competitive disadvantage.

Although some uncertainty remains, tariffs appear here to stay. Multinationals therefore must plan for long-term tariffs, including by adjusting their transfer pricing policies.

Prime Minister Mark Carney rolled out billions of dollars in relief for Canadian businesses and workers battered by tariff wars with the country’s two largest trading partners.

The Thai government has approved proposals for providing for tax incentives to alleviate the top-up tax burdens of large multinational enterprise groups in scope of the country’s global minimum tax regime.

The June G7 side-by-side agreement on the global minimum tax proposal has come under fire for not being effective enough, but there is little to worry about. If anything, it may improve Pillar Two.

The Brazilian tax authority is consulting on draft amendments to its qualified domestic minimum top-up tax, including changes related to the allocation of current covered taxes and deferred taxes and the treatment of securitization vehicles.

The US is considering imposing tariffs in response to an international proposal to charge ships for their carbon dioxide emissions to help fight climate change.

Leaked OECD documents detailing possible pillar 2 amendments, intended to allay the Trump administration's global minimum tax concerns, show that the outcome of these international discussions will present its own challenges in the EU.

Eric M. Lopata examines a common fact pattern that can cause taxpayers to pay global intangible low-taxed income tax on their foreign earnings, even though this residual GILTI tax is not reflective of the local operations or in-country tax paid by a controlled foreign corporation.

The vast majority of President Donald Trump’s tariffs remain in limbo after a federal appeals court ruled that they were issued illegally under an emergency law while agreeing to keep them in place while the case proceeds. The US Court of Appeals for the Federal Circuit on Aug. 29 upheld an earlier decision by the US Court of International Trade. Both courts concluded that Trump wrongfully invoked an emergency law, the International Emergency Economic Powers Act (IEEPA), to justify the duties — a rare rebuke as the courts tend to defer to the president on trade matters.

EU negotiations this fall on a range of corporate tax issues, including the global minimum tax, will be driven largely by President Donald Trump’s demands on the bloc.

Lee A. Sheppard examines the Australian tax reform debate and makes recommendations concerning the country’s taxes on goods and services, individual income, and corporate income, as well as the proposed cash flow tax.

 Leaked OECD documents proposing options for amending the pillar 2 global minimum tax rules in response to concerns from the United States and the business sector provide a rare, behind-the-scenes glimpse into multilateral negotiations.

Renegotiation of the OECD’s tax agreement marks the “crash of global minimum taxation,” a Swiss official said Monday.

What was once too much of a nuisance for the US to regulate became too big of an economic force to ignore any longer.

As President Donald Trump’s tariffs make waves in the world economy, multinational companies are mulling what it could mean for their intangible assets like intellectual property and brand recognition.

Expansion of Canada’s power to gather tax information, as the government is proposing, would open companies and individuals to excessive penalties, more government mistakes, and expensive disputes, tax professionals say.

French President Emmanuel Macron vowed a strong response if any country takes measures that undermine Europe’s digital sovereignty.

Italy is preparing to repeal its digital services tax in the 2026 budget law, according to Finance Ministry sources, after the United States renewed threats to impose tariffs in response to unilateral levies on technology companies.

Reuven S. Avi-Yonah explores the possible outcome if the OECD were to recognize the U.S. global intangible low-taxed income tax as a legitimate pillar 2 income inclusion rule.

Robert Goulder examines the (few) pros and (many) cons of taxing exports.

President Donald Trump threatened to inflict “substantial” tariffs on countries that impose digital taxes just days after Meta Platforms Inc. Chief Executive Officer Mark Zuckerberg raised concerns about the levies during a White House meeting.

Countries that have imposed digital taxes on tech giants such as Amazon.com Inc. and Meta Platforms Inc. are again under threat of retaliatory tariffs from President Donald Trump, forcing them to decide whether to resist or give in to his demands.

The Mexican government plans to increase tariffs on China as part of its 2026 budget proposal next month, protecting the nation’s businesses from cheap imports and satisfying a longstanding demand of US President Donald Trump.

The European Commission denied targeting American companies and defended the EU’s right to regulate businesses within its borders following President Trump’s threats to impose substantial additional tariffs on countries that regulate big tech or impose digital services taxes.

House and Senate leaders will have to reach a deal on funding for the IRS, OECD, and the Justice Department’s plan to reorganize the Tax Division during the upcoming government funding process.

The EU Council’s Danish presidency wants the European Commission to explain how international tax developments could affect incentives to support the Clean Industrial Deal.

Anthony Stobart, Stefano Grilli, Hendrik Breimann, Irene Reoyo, Alice de Massiac, Kristina Adamson, and Shawn Porter summarize the qualified domestic minimum top-up tax rules in Canada, France, Germany, Italy, Spain, and the United Kingdom, providing examples of typical mergers and acquisitions transactions to illustrate their application.

India’s Prime Minister Narendra Modi is seeking to overhaul the country’s complex goods and services tax, in an attempt to boost domestic spending and cushion the economic blow of US tariffs.

The European Union hit back at US President Donald Trump’s claims that digital regulations abroad are unfair, a day after he threatened to impose tariffs and other penalties on countries that tax online services ranging from social media to e-commerce.

Australian Treasurer Jim Chalmers commended a report released by the country’s Productivity Commission that recommends cutting the corporate tax rate and imposing a new tax on cash flow to spur investment and growth.

Reuven S. Avi-Yonah, Jeffery M. Kadet, and Karen Sam refute certain criticism of the proposed cloud services sourcing rules released in January, and they suggest important amendments for Treasury and the IRS to consider in implementing the final regulation.

Craig A. Hillier and Yulia Kirillova review the status of pillar 2 in light of U.S. opposition and they suggest ways to adjust the structure to accommodate the concerns of the United States and other nations while maintaining some of its benefits.

More than two dozen countries criticized a system that would exempt American multinational companies from key parts of the global minimum tax, saying it would risk undermining the tax’s effectiveness, put non-US companies at a disadvantage, and challenge their own tax sovereignty.

US President Donald Trump threatened to impose fresh tariffs and export restrictions on advanced technology and semiconductors in retaliation against other nations’ digital services taxes that hit American technology companies.

Mindy Herzfeld argues that despite the Trump administration’s strong stance against foreign discriminatory taxes, it hasn't taken serious action against them, and says that the administration’s recent deal allowing manufacturers to export AI chips to China closely resembles the types of taxes it disapproves of from other countries.

U.N. countries have very different — and sometimes oppositional — approaches to allocating taxing rights in a digitalized economy, which could complicate negotiations around cross-border services taxation, according to a recent report.

The International Centre for Tax and Development on August 7 issued a policy brief regarding the trade-offs in the U.N. negotiations for protocol 1 to the framework convention on international tax cooperation, finding that protocol 1 needs to address ongoing cross-border taxation issues as digitalization rises; that tax policymaking must be intentional; and that the United States' exit from OECD negotiations limits the potential of a comprehensive international tax standard.

As data centers become a crucial part of global digital infrastructure, revenue authorities worldwide are increasing scrutiny of how such operations may be taxed.

Building a better tax system in Australia is one of the 10 longer-term reform priorities announced by Treasurer Jim Chalmers following a highly anticipated productivity summit with key stakeholders.

Robert Goulder comments on the unexpectedly high U.S. tariffs imposed on Swiss imports.

The OECD has proposed a range of tweaks to the global minimum tax agreement in a bid to quell US concerns about how the regime affects American companies.

Since January 2025, the Trump Administration has raised tariffs on US imports to their highest average levels in recent history, from a universal 10% tariff on virtually all goods imported into the US to a threatened 145% on goods imported from China and varying levels of “reciprocal” tariffs on dozens of additional countries. These tariffs include 25% tariffs on products deemed noncompliant by the administration with the US-Mexico-Canada Agreement (USMCA) update to the North American Free Trade Agreement and 25% tariffs on steel, aluminum, and auto-related products. Other planned tariffs include pharmaceuticals, copper and copper derivatives, semiconductors, and timber and lumber. Further, the US faces retaliatory tariffs from several countries and the European Union.

Treasury and the IRS have decided to withdraw the rules applying disregarded payment losses after concerns about statutory authority led to rounds of delays and additional carveouts.

The U.N. tax committee is looking for input on which tax policy issues it should focus on during its next five-year term.