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Rivkin Radler LLP

Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich

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Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Cadwalader, Wickersham & Taft LLP

Another Step Nearer for CARF in the UK

As announced in the United Kingdom’s Spring Budget for 2024, delivered by the Chancellor of the Exchequer on 6th March, the UK government has published a consultation to seek views on the implementation of the OECD’s flagship...more

Cadwalader, Wickersham & Taft LLP

UK Spearheads Global Commitment to the Crypto-Asset Reporting Framework

The Crypto-Asset Reporting Framework (“CARF”), is the OECD’s flagship tax transparency standard to help combat criminal activity using crypto-assets to evade taxation. The key aspects of the CARF were covered in the article...more

BCLP

Impact of Pillar Two on Tax Risk Apportionment for a Corporate Sale

BCLP on

How do you draft a tax covenant for a corporate sale when the Seller Group is within the scope of a Pillar Two charge? This is an issue that will become increasingly relevant as we approach the Pillar Two start date at the...more

Cadwalader, Wickersham & Taft LLP

Over the Horizon

The resounding theme for the 2023 G20 summit, held on 9th and 10th September in India, has been “Vasudhaiva Kutumbakam” – an ancient Sanskrit phrase meaning “the world is one family.” The term perfectly juxtaposes...more

Ius Laboris

Telework from abroad: tax consequences for employers?

Ius Laboris on

As employers face growing calls to allow employees to ‘work from anywhere’, they should also consider the possible tax consequences of inadvertently creating a permanent establishment in another country. But what counts as...more

Jones Day

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

Jones Day on

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Cadwalader, Wickersham & Taft LLP

EU List of Non-Cooperative Jurisdictions Expanded

On 14 February, the EU Council added four jurisdictions (the British Virgin Islands, Costa Rica, Marshall Islands and Russia) to the list of non-cooperative jurisdictions (Annex I) (the “EU Blacklist”)....more

Cadwalader, Wickersham & Taft LLP

Update: OECD Crypto-Asset Reporting Framework

On 10 October 2022, the Organisation for Economic Co-operation and Development (“OECD”) published the final guidance on the Crypto-Asset Reporting Framework (“CARF”) and a set of amendments to the Common Reporting Standard...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

Cadwalader, Wickersham & Taft LLP

Burlington Loan Management DAC: Treaty Shopping Provisions Did Not Apply

The UK’s First-tier Tribunal recently held that the payment of interest received by Burlington Loan Management DAC (“BLM”) (an Irish tax resident company) was not to be denied the benefits of the relief afforded under the...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

Proskauer Rose LLP on

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Miller Nash LLP

Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies

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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more

McDermott Will & Emery

[Webinar] Tax in the City® - March 1st, 11:30 am - 1:00 pm PDT

The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the City® program of 2022, which will cover federal and...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

Foodman CPAs & Advisors

Out Of Compliance Taxpayers Beware Of The J5

In 2017, following the Panama Papers and Paradise Papers data leaks, the Organization for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. ...more

Jones Day

The UK’s Digital Services Tax: Where Are We Now?

Jones Day on

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

McDermott Will & Emery

[Event] Tax in the City® - June 3rd, Seattle, WA

We invite you to join us for our Tax in the City®: A Women’s Tax Roundtable in Seattle. We plan to discuss, among other topics, post-TCJA tax treatment of foreign branches (and disregarded entities), new BEAT guidance, an...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Tax Strategies in the COVID-19 Economic Downturn: Loss Planning and Transfer Pricing - May 1st, 1:00...

McDermott Will & Emery on

As you assess the operational impact of COVID-19 on your business, you may need to reconsider your tax planning strategies. Join us for a discussion on tax planning opportunities and pitfalls in light of market valuation...more

Dechert LLP

COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities – HMRC Update

Dechert LLP on

Following on from our recent OnPoint (COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities), HMRC has now published guidance on the corporate residence issues posed by COVID-19. ...more

McDermott Will & Emery

[Event] Tax in the City®: A Women's Tax Roundtable - March 12th, Seattle, WA

McDermott Will & Emery on

Mark your calendars for our spring 2020 Tax in the City®: A Women’s Tax Roundtable in Seattle—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and...more

Hogan Lovells

Tech Tax and the OECD: it’s as easy as A, B, C

Hogan Lovells on

What is it about? OECD proposals to tax the digital economy which will significantly impact all large tech companies that are consumer oriented. What will the impact be? Businesses will pay more tax. Impact on cash-flow,...more

Foodman CPAs & Advisors

Four LATAM Countries will work as a TEAM to TACKLE TAX EVASION, Corruption and Other Financial Crimes

The Global Forum and the Organization for Economic Cooperation and Development (OECD) oversee the internationally agreed standards of tax transparency and exchange of information via the Common Reporting Standard (CRS). ...more

Proskauer Rose LLP

UK Tax Round Up - October 2018

Proskauer Rose LLP on

General UK Tax Developments - CIOT responds to the draft profit fragmentation provisions in the Finance Bill 2019 - The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation...more

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