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International Tax Issues Organization for Economic Co-operation and Development BEPS

Katten Muchin Rosenman LLP

Will Pillar Two Crumble Before It's Built?

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

Proskauer - Tax Talks

Trump Administration Disavows the OECD Global Tax Deal

Proskauer - Tax Talks on

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

Akin Gump Strauss Hauer & Feld LLP

The Organization for Economic Co-Operation And Development (OECD) Global Tax Deal (Global Tax Deal)

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

Conyers

Guiding Captives Through Global Developments

Conyers on

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

Holland & Knight LLP

New Multilateral Tax Treaty Implements the Subject to Tax Rule

Holland & Knight LLP on

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

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Freeman Law

Country-by-Country Reporting

Freeman Law on

In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

Miller Nash LLP

When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)

Miller Nash LLP on

The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Cadwalader, Wickersham & Taft LLP

An(other) OECD BEPS 2.0 Update

The release of the Pillar One and Pillar Two “blueprints” in October 2020, and the recent G7 (June 2021) and G20 (July 2021) meetings, provided an opportunity for further progress to be made on the Pillar One and Pillar Two...more

Holland & Knight LLP

Agreement on Global Tax Reform: What Happened and What's Next

Holland & Knight LLP on

Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20...more

Freeman Law

International Tax Treaty: Australia

Freeman Law on

Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

Freeman Law

International Tax Treaty: Mexico

Freeman Law on

The world’s most populous Spanish-speaking nation. Mexico is a Federation comprised of 32 states, being Mexico City the capital of the country. The government of Mexico is divided in three branches: the Legislative Branch in...more

Proskauer Rose LLP

UK Tax Round Up - October 2020

Proskauer Rose LLP on

UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more

Skadden, Arps, Slate, Meagher & Flom LLP

Three Years, Two Pillars and One New Headache for Investment Funds

Fund sponsors, investment advisors and other financial market participants would be forgiven for not concerning themselves with tax initiatives originally targeted at the digital economy. However, with the latest technical...more

BakerHostetler

BEPS 2.0 - International Tax Reform Primer for SALT Experts

BakerHostetler on

It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more

White & Case LLP

Understanding Tax: EU tax challenges for cross border investing and financing

White & Case LLP on

This article is produced by our European Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the international tax environment. The last...more

White & Case LLP

Understanding Tax: The UK as a holding and investment company jurisdiction

White & Case LLP on

This article is produced by our London Tax team, which is part of our global Tax practice. Our series, "Understanding Tax", explores commercially relevant and recent changes to the UK's tax code. The UK as a holding and...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - February 2020

TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - January 2020 #2

TAX TIDBIT - Welcome back from the long weekend in remembrance of Dr. Martin Luther King, Jr., who once said “all labor that uplifts humanity has dignity and importance and should be undertaken with painstaking...more

Morgan Lewis

OECD Proposed Changes to International Tax Regimes May Increase Multinationals' Worldwide Tax

Morgan Lewis on

The Organization for Economic Cooperation and Development recently proposed that consumer-facing businesses that make nonroutine profits would be taxed in market jurisdictions where consumers are located, regardless of where...more

Bennett Jones LLP

Tax Treaty Benefits Threatened as Canada Completes Ratification of OECD's Multilateral Instrument

Bennett Jones LLP on

On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). As noted in our...more

Jones Day

Japan Legal Update - Volume 47 | May–June 2019

Jones Day on

Finance - Amendment to the Payment Services Act Tightens Regulation of Crypto Assets - The Payment Services Act ("PSA") and the Financial Instruments and Exchange Act ("FIEA") were amended on May 31, 2019...more

Bennett Jones LLP

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

Bennett Jones LLP on

On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more

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