Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
10 Things Lawyers Should Know About BVI Transactions
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The Biden Tax Plan
Tax Planning Under a Biden Presidency
2020 Presidential Candidates' Tax Proposals
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Impact of environmental, social and governance agenda on tax
On 4 August 2023, Luxembourg published a bill of law (the “Bill”) to transpose the EU directive no. 2022/2523 largely known as the “EU Minimum Tax Directive” or “Pillar Two Directive”, ensuring a minimum global Effective Tax...more
Earlier this summer, the Group of Seven (G7) held their annual summit to coordinate global policy and devise a plan to help the world build back better from COVID-19. The G7 discussed several priorities and initiatives,...more
The agreement builds on the two-pillar approach outlined by the OECD and aims to tackle the challenges arising from an increasingly globalized and digital economy. Key Points: ..Under Pillar One, the largest and most...more
The General Court has upheld a challenge to a 2016 Commission decision that had required Ireland to recover €13.2 billion in illegal State aid from Apple, on account of alleged preferential tax treatment for the...more
Boeing Co.’s 737 MAX aircraft face continued problems from “potentially hazardous wiring.” European regulators want the manufacturer to relocate some of the wiring to prevent “potential short circuit[s], which in a worst-case...more
Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more
More than a couple of years ago, a lot of fuss was made around the first string of State Aid tax rulings cases of the European Commission (Starbucks, Fiat, Apple, the Belgian scheme relating to the excess profit of...more
OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more
Ireland has an open, pro-business economy that offers significant opportunities to multinational companies, including as a gateway into the European market for US multinationals across all business sectors. Ireland remains...more
Europe’s politicians worry that international tax rules have not kept pace with the digital economy and too easily allow multinationals to organize their global operations to minimize net taxable profits in high-tax European...more
EU opens investigation into UK tax scheme for multinationals - The EU State aid rules are designed to stop Governments and local authorities giving companies a selective advantage, as doing so would create an unequal...more
On 26 October 2017, the European Commission (the Commission) opened an in-depth investigation into UK statutory rules that exempt certain financing income earned by foreign subsidiaries of UK corporate taxpayers from UK tax....more
United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more
King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more
As the European Commission reviews whether tax arrangements conform with State aid rules, companies active in Europe should ensure their fiscal regimes comply with EU law. In recent years, the European Commission (the...more
On 30 August 2016, Ireland was ordered by the EC to recover up to €13 billion from Apple on the basis that tax arrangements implemented between Apple and Ireland, originally in 1991, amounted to the provision of unlawful tax...more
Does the United Kingdom’s vote to leave the European Union change the United Kingdom’s attractiveness as a holding company jurisdiction?...more
The result of the UK’s referendum of 23 June 2016 was announced today as a victory for ‘Brexit’ - in other words, for the UK to exit the European Union. This decision is expected to have significant ramifications for the...more
The June 23, 2016 “leave” Brexit vote has left many in the business and legal communities stunned, and while uncertainties abound, there is no doubt that wading through the economic and administrative complexities of exiting...more
On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed...more
21 October 2015: Following state aid investigations, the European Commission has ordered Luxembourg and the Netherlands to recover unpaid taxes of €20-30m from each of Fiat and Starbucks. The Commission has confirmed that...more
NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more
What the new horizontal tax consolidation regime may mean for private equity sponsors, multinational groups, financial institutions (and everyone else…). In June 2014, the European Court of Justice (ECJ) ruled that the...more
The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more
The European Commission’s Action Plan for Fair and Efficient Corporate Taxation in the EU sets out proposals aimed at making corporate taxation in the EU more transparent and efficient, by reforming a system which is seen as...more