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
On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more
Introduction and Summary - On March 28, 2022, the Biden Administration proposed changes to the U.S. international tax rules. In short, the Biden Administration proposed to: Enact a 15% minimum “undertaxed profits...more
This Holland & Knight alert discusses the intersection of President Joe Biden's proposed changes to the U.S. tax code, as announced in connection with his fiscal year (FY) 2023 budget, and work underway on the global stage...more
TAX TIDBIT - State of the Union Look Ahead. President Joe Biden will make his first State of the Union address tonight before a joint session of Congress. As of this writing, the speech has not been made available to the...more
Yesterday, on December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage. While there are no immediate prospects for the Build Back Better Act to...more
Negotiations Update. After months of negotiation, Democrats appear close to an agreement between the White House, progressives and influential moderate Sens. Joe Manchin (D-WV) and Kyrsten Sinema (D-AZ) on budget...more
TAX TIDBIT - Democratic Patience Wearing Thin. Negotiations around the bipartisan infrastructure framework and the partisan budget reconciliation package continue, but little progress appears to have been made in recent...more
As you may be aware, the House Ways and Means Committee recently approved a multitrillion-dollar tax package (the “Proposal”) that has significant tax impact on both individuals and corporations. ...more
On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more
G-20 leaders meeting in Venice over the weekend took another major step forward in overhauling the international tax system, “backing a proposal that would crack down on tax havens and impose new levies on large, profitable...more
As Congress and the White House look to make a deal on infrastructure by this summer, negotiations regarding changes in the tax law continue. Since our prior alert, while progress has been made regarding a bipartisan...more
On May 28, 2021, the US Department of the Treasury (Treasury) released the Fiscal Year (FY) 2022 budget and Green Book, which provides detailed insights into the proposals of US President Joe Biden’s recently released...more
The G7’s support for OECD-backed tax reforms could mark a big step toward a more consistent, revamped global tax scheme — depending on the details and whether it is actually adopted. ...more
On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more
On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...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
I. Introduction - On May 28, 2021, the Treasury Department released the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook). ...more
Just a few months after regulations were finalized, and as taxpayers were getting comfortable with the international tax provisions implemented by the 2017 Tax Cuts and Jobs Act (TCJA), proposals from President Biden and the...more
Democrats have promised a revamp of the current international tax system to ensure that large multinational corporations pay their “fair share,” stop offshoring jobs, and are incentivized to invest in domestic growth. The...more
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
The Biden-Harris administration announced its American Jobs Plan, a legislative framework laying out an ambitious $2 trillion investment in physical and human infrastructure, on March 31. The bulk of the proposed spending is...more
On Jan. 25, the Senate voted overwhelmingly to confirm President Joe Biden’s nomination of Janet Yellen to be the 78th treasury secretary. Yellen is the first woman to hold the position and she will be responsible for...more