News & Analysis as of

Corporate Taxes Cross-Border Transactions Multinationals

Morgan Lewis

The Dawn of BEPS 2.0 in Singapore: An Uncertain Road, A Certain Destination

Morgan Lewis on

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

Bennett Jones LLP

Canada Introduces "Excessive Interest and Financing Expenses Limitation"

Bennett Jones LLP on

Multinational corporations, cross-border investments and many other Canadian public and private enterprises, will likely soon face a new and complex interest expense deduction limitation in Canada....more

Brownstein Hyatt Farber Schreck

OECD Announces Global Tax Deal

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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Cuts and Jobs Act’s Impact on Cross-Border Transactions

Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more

Brownstein Hyatt Farber Schreck

OECD Publishes Digital Tax Draft Proposal

The Organization for Economic Cooperation and Development (OECD) released a draft proposal today detailing how countries should approach the taxation of multinational companies in an increasingly digitalized global economy....more

Womble Bond Dickinson

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

Womble Bond Dickinson on

OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more

Eversheds Sutherland (US) LLP

We are not in Kansas anymore – OECD proposes way forward for digital tax solution

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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: US Tax Reform and Cross-Border M&A: Considering the Impact, One Year In

Many of the core provisions in the Tax Cuts and Jobs Act (TCJA) — including the corporate tax rate reduction and the fundamental reworking of the U.S. international tax regime — were geared toward addressing the uncompetitive...more

Latham & Watkins LLP

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Latham & Watkins LLP on

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

Hogan Lovells

What is the MLI and why is it important in the context of the South African tax system

Hogan Lovells on

The Base Erosion and Profit Shifting (BEPS) Project of the OECD was launched with the publication of the OECD BEPS Action Plan in 2013. The BEPS Project comprised various "Actions" aiming to fight tax avoidance strategies...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Enacts the Most Comprehensive Changes in Three Decades

The sweeping tax bill that President Donald Trump signed into law on December 22, 2017, represents the most comprehensive reform of U.S. tax law since 1986. The law makes substantial changes to the taxation of individuals and...more

Hogan Lovells

Budget 2017

Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Seyfarth Shaw LLP

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

Seyfarth Shaw LLP on

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

Bennett Jones LLP

International Tax & Transfer Pricing Strategies in the Crosshairs

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The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

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