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GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
Ley Mbappé
Nonprofit Basics: International Grantmaking Part 3 -Special Rules for Private Foundations
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
At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more
Le Conseil d’Etat confirme l’existence d’un établissement stable et caractérise une activité occulte en l’absence de déclaration de cet établissement en France par application de l’article L. 169 du Livre des procédures...more
The Trump administration has declared that prior U.S. commitments under the OECD’s Pillar Two agreement would have no domestic effect unless approved by Congress, reflecting long-standing opposition....more
The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more
Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane...more
Tax developments - Other countries’ response to United States position on the Global Tax Deal - On Friday, President Trump issued a memo discussing his administration’s intent to defend US companies from unfair foreign...more
Within the first month of President Trump’s second term, the nation has witnessed several executive actions relating to tax and tax administration that affect American businesses and consumers. This article summarizes some of...more
Over 135 jurisdictions signed up for a global Organisation for Economic Cooperation and Development (OECD) project in October 2021 aimed at reforming the international taxation system. A Two-Pillar approach was developed to...more
On his first day in office, among the numerous Executive Orders (EO) released, President Donald Trump announced the America First Trade Policy EO designed to prioritize American interests in international trade and tax and,...more
Since assuming office on January 20, 2025, President Donald Trump has prioritized tax policy, issuing a series of directives aimed at boosting economic growth and advancing the “America First” agenda. On his first day in...more
As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more
Day one of the Trump administration and the impact of the new U.S. President and Republican-controlled House and Senate is being felt in many areas, including in the international tax sphere. On 20 January, President Trump...more
On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more
Issues a memorandum rejecting U.S. commitments related to the OECD Global Tax Deal unless enacted by Congress. It directs the Treasury and USTR to identify extraterritorial taxes and tax practices disproportionately impacting...more
Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with...more
Jersey has passed legislation to implement the OECD's global minimum tax rate of 15%, known as "Pillar 2", which will apply for fiscal years commencing on or after 1 January 2025....more
On September 10, 2024, the European Court of Justice (ECJ or Court) sided with the European Commission (Commission) and ruled that two Irish subsidiaries of Apple Inc. received unlawful state aid from Ireland in the form of a...more
The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more
Following on from the Crown Dependencies re-affirming their commitment to implementing the Organisation for Economic Co-operation and Development’s Pillar Two framework for accounting periods commencing on or after 1 January...more
In October 2020, the Organization for Economic Co-operation and Development (“OECD”) Secretariat released a report addressing its “Pillar Two” blueprint for an overhaul of the international tax system. Pillar Two provides for...more
The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more
Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more
The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more
Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more
More than 135 jurisdictions since October 2021 have joined a groundbreaking plan to address certain tax challenges of the new digital and global economy. The plan consists of a Two-Pillar Solution to update key rules of the...more