Our “GILTI Conscience” team was joined by colleagues Paul Oosterhuis and Eric Sensenbrenner to discuss what companies can expect now that Pillar Two implementation is becoming a reality. ...more
On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more
In the new episode of our tax podcast, “GILTI Conscience,” partners Nate Carden and David Farhat speak with Skadden of counsel Paul Oosterhuis and associate Huzefa Mun about tax legislation, including how the potential...more
On September 24, 2019, the EU General Court (General Court) issued its long-awaited judgments in relation to the appeals brought against two European Commission (EC) decisions of 2015 concluding that tax rulings granted by...more
9/30/2019
/ Arm's Length Principle ,
Benchmarks ,
Business Profits ,
Corporate Counsel ,
Corporate Taxes ,
European Commission ,
Fiat ,
General Court of the European Union (GCEU) ,
Luxembourg ,
Member State ,
Netherlands ,
Regulatory Authority ,
Starbucks ,
State Aid ,
Tax Litigation ,
Treaty on the Functioning of the European Union (TFEU)
On January 25, 2017, Skadden hosted a panel discussion at the London Stock Exchange on the potential policy direction of the Trump administration. The panel touched on tax reform, trade agreements, inbound and outbound U.S....more
2/14/2017
/ Acquisitions ,
Antitrust Investigations ,
Economic Sanctions ,
EU ,
Foreign Investment ,
Global Economy ,
International Relations ,
London Stock Exchange ,
Mergers ,
Multinationals ,
National Security ,
NATO ,
Repatriation ,
Repeal ,
Russia ,
Tax Reform ,
Trans-Pacific Partnership ,
Trump Administration ,
UK ,
Ukraine
On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would become retroactively effective to April 4, 2016, and dramatically alter the tax...more
On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more
9/21/2015
/ Aggregation Rules ,
Arms Length Transactions ,
Controlled Transactions ,
Covenant of Good Faith and Fair Dealing ,
Foreign Corporations ,
Internal Revenue Code (IRC) ,
IRC Section 367 ,
IRS ,
Ordinary Business Exception ,
Outbound Transactions ,
Section 482 ,
Transfer Pricing ,
U.S. Treasury ,
Valuation
On Wednesday, the U.K. Government released draft legislation to be effective on 1 April 2015, which will impose a “diverted profits tax” (DPT) at 25 percent of the amount of profits deemed to have been diverted from the U.K....more
On March 24, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on the tax challenges facing the digital economy (the DE Report). This draft report is issued in...more
Three significant international tax reform proposals in the United States have been released in the past three years: the International Tax Reform Discussion Draft released by House Ways & Means Committee Chairman Dave Camp...more
On November 19, 2013, Sen. Max Baucus (D-Mont.), Chairman of the Senate Finance Committee, released a Staff Discussion Draft on International Business Tax Reform. The changes proposed in the discussion draft are far-reaching...more
Introduction -
Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more