Foreign Tax Double Taxation

News & Analysis as of

BEPS: OECD Releases Multilateral Tax Treaty Convention

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more

PPL Corp. v. Commissioner of Internal Revenue

Brief For Southeastern Legal Foundation, Chamber of Commerce of the United States of America, CATO Institute, et al, As Amici...U.S. Supreme Court

PPL, an American energy company, bought one of many state-owned British utilities privatized in the 1980s. In 1997, PPL became subject to the U.K.’s new “windfall tax,” which was based in part on “profit-making value”— the...more

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