Reframing Digital Tax: Next Up, AI
Herzfeld argues that international tax policy debates remain focused on the digital economy even as artificial intelligence is reshaping how businesses generate profits. The rise of AI challenges core tax concepts such as permanent establishment, nexus, and the transfer pricing framework built around DEMPE functions and human value creation. She suggests that massive investments by U.S. tech companies in AI infrastructure and the growing role of proprietary data may require policymakers to rethink how taxing rights and profits are allocated globally.
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Mike Pence Group Chides Trump Tariffs for Hurting US Job Market
President Donald Trump’s fluctuating tariffs have weighed down US job growth with rising costs and uncertainty for companies, according to a new memo from the group founded by former Vice President Mike Pence.
HMRC Issues Paper on Corporate Tax Regime Reforms
HM Revenue & Customs released a policy paper outlining reforms to the U.K.’s advance corporation tax (ACT) regime aimed at simplifying the treatment of surplus ACT balances. The measure will remove the “shadow ACT” rules that previously restricted companies’ ability to offset unrelieved ACT balances against corporation tax liabilities. Effective for accounting periods ending on or after April 1, 2026, the reform is expected to simplify corporate tax compliance and allow companies to utilize remaining ACT credits more efficiently.
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US Tax Carveout Is a Good Step Toward Needed Cross-Border Work
EU members are beginning to implement the side-by-side agreement reached by the G7 last year—a deal that put the US and OECD global minimum tax frameworks on equal footing. This is an important step in international economic relations, which have been frayed by hostility over discriminatory policies.
US Firms Likely to See Relief From Global Minimum Tax Dilemma
American companies are feeling the pinch of the global minimum tax, but their bills will shrink after a US exemption from the levy kicks in and countries begin to offer new tax incentives to maintain foreign investment.
The Unexpected Winners From Trump’s New Global Tariff
The president’s flat 10 percent tariff on imports could reshape global trade patterns, benefiting some countries that previously faced higher tariff rates while raising questions about the broader impact on imports.