The OECD-G20 BEPS Project's goal is ciclopeous: Making the global tax environment fairer than ever by closing loopholes and adopting rules of international law which would be domesticated…
On 11 February 2015 a US District Court found that the US Internal Revenue Service disclosed false tax return information to the Japanese National Tax Administration contrary to the Japan-US tax…
If time allows, I try to contribute to the OECD discussions submitting comments to their draft papers. Last November and December 2014, the OECD came out with several drafts for discussion (this…
The OECD Joint Working Group on Business Restructurings is, in many respects, the precursor to the OECD BEPS project. Unresolved Business Restructuring issues, particularly in relation to permanent…
