GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
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
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
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
Both Congress and the executive branch have been considering the notion of a new regulatory regime to limit certain types of US outbound investment in other countries. While such a regime would certainly constitute a sea...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 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 Office of the United States Trade Representative (“USTR”) announced that the Department of the Treasury has reached an agreement with Austria, France, Italy, Spain, and the United Kingdom regarding the treatment of...more
Today, the Office of the U.S. Trade Representative (USTR) announced an agreement reached with five countries – Austria, France, Italy, Spain, and the United Kingdom – on digital services tax (DST) measures that had been...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
UK Case Law Developments - Tax avoidance motive did not prevent availability of share for share exchange treatment - In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...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
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
Lighthizer testified that tariffs will be imposed if trading partners enforce digital service taxes. The Organisation for Economic Co-operation and Development’s (OECD) Inclusive Framework aims to reach an agreement on a...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
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
On July 10, 2019, the US Trade Representative (USTR) initiated an investigation under Section 301 of the Trade Act of 1974 (Trade Act) with respect to France’s new Digital Services Tax (DST) Act (LOI n° 2019-759 du 24 juillet...more
This Week: USTR holds hearing on French digital services tax; EU to consider new regulation governing online platforms; Sanders, Warren take on facial recognition technology in new criminal justice reform proposals....more
On July 11, 2019, the French Parliament adopted the bill creating a tax on digital services, applicable as from January 1, 2019. Failed International Attempts - The desire to adjust tax policy in the digital age is not...more
The Office of the U.S. Trade Representative (“USTR”) announced on July 10 the initiation of an investigation under Section 301 of the Trade Act of 1974 into France’s digital services tax (“DST”). The French Senate...more
Relief from Unfair Imports of Plastic Retail Carrier Bags to Continue for Five More Years - On April 27, the International Trade Commission (Commission) issued the public views of its unanimous determination in favor of...more
Hearings held by the U.S. Trade Representative (USTR) and Congressional Steel Caucus during April 12-14 provided a direct look at how steel overcapacity in foreign countries has drastically affected the domestic steel...more