AI Around the Globe: What to Know in 2024
GILTI Conscience Podcast | Amount B Back in the Spotlight
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
Podcast: Digital Taxation—Implications for EU Technology Companies
Podcast: Credit Funds: Withholding Tax on European Investments
New anti-abuse provisions
FCPA Compliance Report-Episode 333, Professor Samuel Buell
FCPA Compliance Report-Episode 329, James Koukios
The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the...more
In December 2021, Canada announced plans to impose a digital services tax, or DST. A few days later, the Office of the US Trade Representative (USTR) expressed opposition indicating that if Ottawa were to pursue this plan,...more
On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC) for certain foreign withholding taxes...more
On November 19, the Office of the US Trade Representative (USTR) announced that it would terminate the actions it had taken under Section 301 of the Trade Act of 1974 with respect to digital services taxes (DSTs) adopted by...more
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
On 8 October 2021, the OECD released a further statement in relation to the BEPS 2.0 proposals, aimed at addressing taxation of the modern digital economy. This is the latest development in the attempts to more equally share...more
On Friday October 8, 2021, the Organization for Economic Cooperation and Development (OECD) announced that 136 Nations, including the United States and the rest of the G20, have signed on to the OECD/G20 Inclusive Framework...more
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
To date, 132 jurisdictions have committed to the OECD’s two-pillar plan to reform international tax rules, as set out in its statement of 1 July 2021. Although the genesis of the proposed reforms relates to the taxation of...more
The United States Trade Representative (“USTR”) Katherine Tai announced 25% additional tariffs on approximately $2 billion worth of imported goods from Austria, India, Italy, Spain, Turkey, and the United Kingdom (“UK”),...more
While much of the focus has remained on the efforts of the Organisation for Economic Cooperation and Development (OECD) with respect to digital taxation, the United Nations (UN) has finalized revisions to the UN Model Double...more
As the global economy rapidly shifts and accelerates, the OECD has been focusing intently on developing and strengthening international tax rules in recent years. Back in February 2013, the OECD released a report addressing...more
The United States Trade Representative (“USTR”) announced the continuation of certain Section 301 investigations related to digital services taxes (“DSTs”) and the termination of certain others. USTR originally initiated...more
Unilateral steps in a growing number of countries to raise tax revenue from digital services have raised global alarm in recent years, but they have particularly heightened concerns in the United States due to the...more
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
This week: Coronavirus response; G20 finance officials express renewed hope for digital services tax deal this year; App Coalition hosts Section 230 Virtual Summit; FCC kicks off first 5G mid-band spectrum auction....more
Current Status: The UK Government is moving ahead with its implementation of the Digital Services Tax ("DST") despite concerns raised by the United States and the Organisation of Economic Co-operation and Development ("OECD")...more
With effect from 1 April 2020, the UK will start to levy a digital services tax at a rate of 2% on digital services revenues that are attributable to UK users. The UK digital services tax (“UK DST”) is intended to apply to...more
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
There have been several recent developments in trade disputes involving the Trump Administration and the European Union (EU), including an increase by the U.S. Trade Representative in tariffs on new Airbus aircraft and...more
On December 2, 2019, the U.S. Trade Representative (USTR) announced that in response to a digital services tax law passed in France, it would be retaliating with stringent tariffs on luxury products coming from France. The...more
Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more
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
This Week: House Energy and Commerce circulates staff draft privacy legislation, Democratic bill would direct HHS to study Section 230 carveout, Canada to move ahead with digital services tax as U.S. proposes safe harbor,...more
On December 2, 2019, the Office of the US Trade Representative (USTR) announced its determination that France's Digital Services Tax (DST) is "unreasonable or discriminatory and burdens or restricts U.S. commerce" and is...more