Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS)…
Our 14-page comments and recommendations of 14 tax professionals and academics from 11 countries raise additional issues and concerns, and propose additional recommendations to undertake a detailed…
We applaud the OECD’s 15-year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of…
In my International Taxation class tomorrow (October 10th) we are going to discuss the OECD's “Unified Approach” released a day earlier on October 9, 2019. Given the keen interest generated by…
William Byrnes, Texas A&M University School of Law* (33-page draft research available on SSRN)
Howdy! Earlier today the General Court of the European Court of Justice (EGC) sided with Starbucks’…
I have received several requests this July 4th holiday in the U.S. about my initial thoughts on the EU Commission's 56-page published (public version from earlier this week) State Aid preliminary…
In a double take two-to-one decision because of a withdrawn decision due to the death of a judge, a Ninth Circuit panel in Altera reversed a unanimous en banc decision of the Tax Court that the…
In regards to the title of this post, the Ways & Means version of international tax reform moves toward a territorial regime of granting an exemption for foreign profits but then derogates from the…
IRS Operational Update: Reorganization and Risk-Based Approach
The IRS new Large Business and International (LB&I) risk approach has been implemented in the form of “campaigns”, focusing on weighing…
