Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
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 - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
Musings on Multinational Tax: What to Expect From GILTI Conscience
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
Challenges for Infrastructure Projects in the Current Environment
Podcast: Digital Taxation—Implications for EU Technology Companies
Podcast: Cum-Ex Dividend Trade Investigations
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
Join Womble Bond Dickinson and Houston ACC for a panel discussion on the legal aspects and practical considerations when expanding your operations internationally. We’ll cover different types of presences, tax considerations,...more
For investors in enterprises in the Korean semiconductor industry and other national strategic industries, a new tax bill has been passed that (i) increases the base tax credits received by these enterprises to 25% (if...more
The UK continues to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more
The global wave of the two-pillar solution to address base erosion and profit shifting, commonly known as BEPS 2.0, has formally washed ashore in Singapore. It is now certain that multinational enterprises (MNEs) with local...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more
In the new episode of our tax podcast, “GILTI Conscience,” EY’s Michael McDonald discusses whether the OECD’s DEMPE transfer pricing guidelines are being properly interpreted, including whether some jurisdictions are placing...more
The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the City® program of 2022, which will cover federal and...more
Businesses that conduct operations both inside and outside of the United States and own U.S. and non-US-related intellectual property (e.g., patents, copyrights, trademarks, etc.) routinely face uncertainty about whether some...more
Skadden is proud to present "GILTI Conscience," a new podcast series in which tax partners Nate Carden and David Farhat invite other industry leaders and authorities to join them in discussing pressing transfer pricing...more
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more
The Organization for Economic Cooperation and Development (OECD) announced earlier today that 136 countries reached agreement on the Inclusive Framework on Base Erosion and Profit Shifting. The two-pillar framework would...more
Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more
According to the OECD Secretary-General Report to G20 Finance Ministers dated July 1, 2021 (OECD Report), 130 member jurisdictions of the G20/OECD Inclusive Framework on BEPS (Base Erosion and Profit Shifting), representing...more
The release of the Pillar One and Pillar Two “blueprints” in October 2020, and the recent G7 (June 2021) and G20 (July 2021) meetings, provided an opportunity for further progress to be made on the Pillar One and Pillar Two...more
Though effective since January 2021, the Spanish Digital Services Tax has still not been fully implemented. The approval of the regulations and the tax return allow to better understand the material and formal obligations...more
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more
On 4 and 5 June 2021, the Finance Ministers and Central Bank Governors of the G7, joined by the Heads of the International Monetary Fund, World Bank Group, Organisation for Economic Cooperation and Development, and Eurogroup,...more
The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more
Effective as of 16 January 2021, a new Digital Services Tax has come into force in Spain. The rate is 3% and it is levied on certain digital services provided by large multinational companies with the participation of users...more
Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more
It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more
Covid-19 is creating unexpected tax exposure for foreign-based businesses with employees detained in the US and vice versa as companies may now find themselves with more sourced income than expected causing unforeseen tax...more
The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more