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William Byrnes  (Texas A&M University Law)
Heads I Win, Tails You Lose. Or is an APA a contract subject to contract law?
August 29, 2022

On August 25, 2022, the Sixth Circuit Court of Appeals answered a fundamental question about advance pricing agreements (APAs): Is an APA a contract between the IRS and a taxpayer?[1] If it is a…

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Guillermo O. Teijeiro  (Bomchil)
Argentina: Taxation without representation or how to disguise a new tax under the form of an additional prepayment of Income Tax
August 25, 2022

Main features of the new extraordinary prepayment on account of Income Tax  General Resolution 5248/22 (the Resolution), issued by the Argentine Tax Agency (AFIP), and gazetted on August 16, 2022…

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William Byrnes  (Texas A&M University Law)
Medtronic I, II, and III - Who won? The IRS or the Taxpayer?
August 22, 2022

On Thursday, August 18, 2022, Chief Judge Kathleen Kerrigan of the U.S. Tax Court published her 75-page decision on the Medtronic and I.R.S. controversy (“Medtronic III”).[1] This decision resulted…

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Ana Paula Dourado  (General Editor of Intertax)
The Contents of Intertax, Volume 50, Issue 8-9, 2022
August 19, 2022

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Zhe Chen & Bart Peeters, A Study on the Protection of Taxpayer Rights in…

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Pedro Guilherme Lindenberg Schoueri  (PhD by the Vienna University of Economics and Business and Tax Associate in Sao Paulo) , Ricardo André Galendi Júnior  (Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados)
Who is the “taxpayer” for the IIR and why it does matter
August 16, 2022

1. The IIR and the top-down approach It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a…

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PD Dr. Thorsten Helm  (Public Sector Tax, Partner KPMG Germany ) , Christian Bischoff  (Public Sector Tax, Senior Associate, KPMG Germany)
 A statute for European cross-border associations and non-profit organizations – A new dawn for European regulatory harmonization in the non-profit sector?
August 15, 2022

As it currently stands, the legal and policy framework for non-profit organisations and foundations within the European Union differ – in some cases slightly, in others significantly. This regularly…

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Ben Kiekebeld  (General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)
The Contents of EC Tax Review, Volume 31, Issue 4, 2022
August 09, 2022

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Lily Zechner, Understanding VAT in Three-Party, Platform-Based Business…

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Raffaele Russo  (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Chiomenti) , Giorgio Beretta  (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)
Making Cash(less) King: Italian Lessons on Digital Payments and Tax Compliance
July 26, 2022

The transition toward a cashless society is at the heart of many public policy discussions. The move is driven by several factors, such as the spread of debit and credit cards, the development of…

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Giorgio Beretta  (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University) , Dennis Weber  (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)
The Contents of Highlights & Insights on European Taxation, Issue 7, 2022
July 22, 2022

Highlights & Insights on European Taxation Please find below a selection of articles published this month (July 2022) in Highlights & Insights on European Taxation, plus one freely accessible…

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Stefanie Geringer  (University of Vienna)
Greening the EU VAT Rate System: The Case for a Differentiated Assessment
July 19, 2022

The EU VAT Rate Reform 2022, Including a Two-Pronged Approach to Align the EU VAT Rate System with the Green New Deal In April 2022, the Council of the European Union adopted a Directive (2022/542)…

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