1. IntroductionThe global minimum tax (Pillar Two) was implemented in the European Union in December 2022 through Directive (EU) 2022/2523 . At its core lies a system of “top-up tax” whereby the…
Trump wasted no time. Just over a month after the 20 January Memoranda, the President issued a new Memorandum on 21 February, this time setting his sights squarely on the digital sector. Presented as…
Introduction
A few weeks ago, the US Trump administration announced its departure from the so-called ‘global tax deal’, which includes all negotiations at the Inclusive Framework both regarding the…
*This post was first published on the website of Maastricht University*
In recent weeks the tax world gave a lot of attention to how President Trump blew up some serious advancements in…
On Friday, the U.S. Supreme Court issued its expected overruling of the Chevron doctrine, which has been relied upon in 70 past Supreme Court decisions and approximately 17,000 in the Appellate and…
At the end of 2017, Congress passed a once-off Mandatory Repatriation Tax (the “MRT”) of 8 to 15.5 percent of the undistributed total accumulated income of American-controlled foreign corporations…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Jeroen Lammers & Błażej Kuźniacki, The EU Solidarity Contribution and a…
The inspiration for this post is “The Made In America Tax Plan” (https://home.treasury.gov/system/files/136/MadeInAmericaTaxPlan_Report.pdf) recently released by the U.S. Department of the Treasury…
Raffaele Russo[1]
"In those countries where income taxes are lower than in the United States, the ability to defer the payment of U.S. tax by retaining income in the subsidiary companies provides a…
