News & Analysis as of

UK Targets Corporate Profits Of Multinational Enterprises With Sweeping Tax Changes

On December 3, the UK Government announced its intention to introduce a new “diverted profits tax” (DPT) to take effect on April 1, 2015. Draft legislation was published on December 10 and is now subject to a public...more

Autumn Statement 2014

On December 3, 2014, George Osborne delivered his Autumn Statement. Traditionally, the purpose of this has been to update economic projections and department spending allocation, but increasingly it includes statements...more

As Congress Seeks Additional Funding, Inversion Proposal Emerges

Throughout the past several weeks, Pfizer’s attempt to acquire AstraZeneca has garnered significant congressional and media attention. Pfizer, a U.S. multinational corporation, made a bid for AstraZeneca in an effort to move...more

Implications of a Switch to a Territorial Tax System in the United States: A Critical Comparison to the Current System

I. Introduction and Executive Summary - This paper examines the effects of a switch in the U.S. corporate tax system from the current worldwide tax system with deferral to a territorial tax system consistent with those...more

Legislative Update Tax Reform—A Work in Progress

With high tax rates and a worldwide (as opposed to territorial) system of taxation, U.S. corporate tax laws encourage new multinational corporations to organize outside the U.S. and encourage existing U.S. corporations to...more

India at the Crossroads

India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more

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