2026

A year into the Trump administration’s global tariff campaign, many companies are still struggling to coordinate their trade functions with their tax and transfer pricing teams, risking messy audits in the years to come.

The article reports on Turkey’s proposed tax package to attract foreign investment, regional operations hubs, exporters, and high-net-worth immigrants. The proposal would provide major corporate tax exemptions for qualified service centers, reduced tax rates for export income, a long-term foreign-source income exemption for qualifying new residents, and an amnesty for funds transferred into Turkish financial institutions.  

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The article examines European and business concerns over California A.B. 1790, which would phase out the water’s-edge election and require worldwide combined reporting for multinational corporations doing business in California. Mandatory worldwide combined reporting could lead to double taxation, increased compliance burdens, and foreign government objections by applying California’s formulary apportionment system to global corporate income.  

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The article reports that Portugal plans to propose a windfall tax on energy companies that have benefited from higher prices linked to the Iran war. The proposal builds on Portugal’s 2022 excess profits tax and follows unsuccessful efforts by Portugal and other EU countries to push the European Commission toward an EU-wide energy-sector windfall tax. The article shows how governments are reviving excess profits taxation as a national fiscal response to geopolitical shocks, energy price volatility, and public pressure over corporate gains during crises.

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The article reports that Switzerland is considering delaying the application of OECD Pillar 2 guidance on deferred tax assets from tax years beginning in 2024 to tax years beginning in 2025. The guidance affects how preexisting deferred tax assets tied to government arrangements or new corporate tax regimes are treated in effective tax rate calculations under the GloBE rules and Switzerland’s qualified domestic minimum top-up tax.

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The article examines how FIRPTA’s treatment of intangible rights remains unclear for transportation infrastructure projects, even as foreign investment in AI-related data centers and supporting infrastructure becomes increasingly important. Yu argues that while recent FIRPTA reforms and REIT structures provide clearer treatment for data center investment, foreign investors in public-private transportation concessions still face uncertainty over whether operational permits, licenses, and tolling rights constitute U.S. real property interests.  

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The European Union wants the main parts of a US trade deal adopted by July, as it pushed Washington to respect previous commitments made under the pact.

The article discusses disagreement among EU member states over whether windfall taxes on energy companies should be imposed at the EU level or left to national governments. Germany, Austria, Portugal, and Spain supported an EU-wide approach, while the Eurogroup president emphasized that taxing windfall profits remains a national policy decision that must take into account energy security, supply chains, and infrastructure investment.  

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The article examines renewed calls for a windfall profits tax on oil and gas companies following price increases tied to conflict in Iran. It discusses the political and practical difficulties of imposing sector-specific taxes, including concerns about revenue generation, energy markets, and long-term investment incentives. 

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The article criticizes Germany’s Federal Central Tax Office for denying treaty-based withholding tax relief to U.S. investors in German entities treated as fiscally transparent under the U.S. check-the-box rules. The authors argue that Germany’s position misapplies Article 1(7) of the Germany-U.S. tax treaty by focusing on the classification of the German payer rather than whether the income is taxed at the U.S. resident level.  

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