2025

The G20 will keep negotiations going on a proposal to shield U.S. companies from the application of some OECD pillar 2 global minimum tax rules, according to a communiqué issued after a key meeting.

Lee A. Sheppard examines a provision in the One Big Beautiful Bill Act that restores, with some exceptions for specified foreign parent situations, the prohibition on downward attribution that the Tax Cuts and Jobs Act repealed, saying that the IRS and Treasury will need to rescind or reengineer guidance issued while the prohibition was repealed.

The White House says the EU is committed to abandoning its future plans to impose network fees on big U.S. tech platforms; the European Commission is less sure.

The OECD on July 17 published a report — prepared ahead of the July 17-18 meeting of G20 finance ministers and central bank governors in South Africa — regarding recent developments in international tax cooperation, including its support of various G20 priorities such as tax transparency and the implementation of the base erosion and profit-shifting minimum standards.

Adam Kern analyzes how treating global intangible low-taxed income as an income inclusion rule will affect the stability of pillar 2.

Patrick Driessen argues that the similarity between the U.S. base erosion and antiabuse tax and digital services taxes undermines the United States’ criticism of DSTs.

Lee A. Sheppard explains important 2024 tax developments in the European Union, including key tax decisions in the EU’s Court of Justice.