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Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate program.AbstractThe European Union has transposed Pillar Two into EU law,…

Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programAbstractWe appreciate this opportunity to provide article-by-article…

On September 25, 2025, Perrigo v. U.S. was decided, marking a significant win for the taxpayer, particularly in the Court’s finding regarding economic substance and risks. The Federal Judge in the…

Written version of the speech delivered on 21 November 2025 during Assonime’s second International Tax Conference in RomeLadies and gentlemen, colleagues, dear friends,Thanks for the invitation to…

 Assonime’s second International Tax Italian Conference confronts the side-by-side eraFederico De Alfieri  – Nicola Vernola Tax experts, business leaders and policymakers convened in Rome on 21…

In my Kluwer article of February 11, 2023, The 3M Decision: Did Treasury or Congress Overturn Past Jurisprudence? I predicted that the Eighth Circuit Court of Appeals would likely overturn the Tax…