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Comparison of the Biden Administration and Senate Finance Committee International Tax Proposals

On March 31, 2021, the Biden administration released a factsheet for the “Made in America Tax Plan”. On April 5, 2021, Senate Finance Chair Ron Wyden (D-Ore.) and Senators Sherrod Brown (D-Ohio) and Mark Warner (D-Va.)...more

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

IRS Proposes Country-by-Country Reporting Regulations

On December 21st, 2015 the IRS proposed Country-by-Country (“CbC”) reporting rules requiring certain U.S. multinational companies to provide extensive information about business operations (including their revenue, number of...more

New Developments on International Automatic Financial Information Exchange and Disclosure

We last updated our clients and friends in February 2014 (Feb 2014 Memorandum) on issues related to the disclosure and automatic exchange of financial information on an international basis. Since then, the pressure...more

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