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
Maximiliano Concha Rodríguez is counsel with PAGBAM | Schwencke, Chile, the ILN's member firm. In this episode, Lindsay and Max chat about the unending tax reforms in Chile, the recent tax treaty between the US and Chile, and...more
On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more
On May 17, 2024, the Office of the Attorney-General of the National Treasury (“PGFN”) and the Brazilian Internal Revenue Service (“Brazilian IRS”) jointly published the Public Notice of Settlement for Adhesion No. 6/2024...more
On May 13, 2024, the Attorney General's Office of the National Treasury published PGDAU Public Notice No. 2/2024, which creates a new tax settlement method for credits enrolled into federal overdue tax liability, with or...more
On April 24, 2024, the Executive Branch introduced Complementary Bill of Law No. 68/2024 ("PLP 68" or the “Bill”), which creates the Tax and the Contribution on Goods and Services ("IBS" and "CBS") as well as the Selective...more
Following the UK Government’s 6 March announcement of tax reforms for the current “non-dom” tax regimes, the opposition Labour party has begun to outline how its plans would differ if they win the next UK general election. In...more
The Brazilian Tax Reform on consumption was enacted through Complementary Amendment No. 132/2023, which unified the main taxes on the consumption of goods and services in the form of a Dual VAT and through the creation of a...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
The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more
Below we list some key tax legislative changes that are relevant to new investments in infrastructure projects and that are already in force or have been announced by the government and are under discussion in the National...more
Several new rules were approved on December 28, 2023, all extremely relevant to tax law. Our tax team summarizes some of the more relevant new rules...more
Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more
On December 21, 2023, the Brazilian Federal Revenue enacted Normative Instruction No. 2,167/2023 ("the Instruction"), which was published in the Federal Official Gazette. The Instruction provides rules for the standardization...more
After more than two decades of discussions, the National Congress approved, and the President of the Republic enacted the final text of the Constitutional Amendment n. 132/2023, known as the Brazilian Tax Reform on...more
The German legislator is currently planning a number of changes that will have a significant impact on taxpayers, including, in particular, the Act to Strengthen Growth Opportunities, Investment and Innovation as well as Tax...more
Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more
On August 4, 2023, the Department of Finance released an updated version of the draft legislation that will incorporate the excessive interest and financing expense limitation rules (“EIFEL Rules”) into the Income Tax...more
Our “GILTI Conscience” team was joined by colleagues Paul Oosterhuis and Eric Sensenbrenner to discuss what companies can expect now that Pillar Two implementation is becoming a reality. ...more
Since the 1990s, Latin American states have sought to attract large-scale foreign investment by implementing specific policies and regulatory regimes aimed at attracting investors from abroad. This trend has, however,...more
House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more
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
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
2023 is set to be a year of change for the global tax landscape. After many years of negotiation, development and consultation, implementation of the OECD’s Pillar One and Pillar Two reforms to international taxation is now...more
Election Results - Results are accurate as of 2 p.m. ET. - Following record-breaking turnout in yesterday’s midterm elections, control of the 118th Congress remains unknown. Even as polling in the two weeks leading up...more
The past week was a busy one for Canada’s Department of Finance (“Finance”). On November 3, 2022, Finance released its 2022 Fall Economic Statement (the “Fall Economic Statement”) and the following day, it introduced Bill...more