Beginning July 12, 2023, the European Commission (Commission) may begin “ex officio” investigations of financial contributions that companies receive from non-EU governments. The Commission may request information or conduct...more
5/12/2023
/ Compliance Dates ,
Countervailing Duties ,
Disclosure Requirements ,
EU ,
European Commission ,
Foreign Subsidies ,
Government Investigations ,
Multinationals ,
New Guidance ,
State Aid ,
Unfair Competition ,
WTO
A new report (the Report) published by the German Federal Ministry of Finance (the MOF) suggests that there may be some forthcoming relief for taxpayers impacted by a nearly century-old tax provision which requires...more
Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more
7/6/2021
/ Affiliates ,
Business Profits ,
Foreign Profits ,
IRS ,
Medical Devices ,
Medtronic ,
Multinationals ,
Parent Corporation ,
Popular ,
Puerto Rico ,
Tax Court ,
Transfer Pricing
On February 11, 2021, the German Federal Ministry of Finance (GFMF) published a decree (the Decree), confirming their position that German withholding tax (at a rate of 15.825%) is due and payable on gross royalties that are...more
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan with respect to base erosion...more
2/4/2019
/ BEPS ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cross-Border Transactions ,
Digital Services ,
Foreign Tax Credits ,
GILTI tax ,
International Tax Issues ,
Multinationals ,
OECD ,
WTO
On November 16, 2017, the House of Representatives passed a much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The passage of the House Plan...more