What do these two things have in common? Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean's Endowed Chair, Texas A&M School of Law explains
In 1998, seven US heavy-duty diesel engine (HDDE)…
MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors published a technical…
As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…
In the last few months I have been deeply committed with the Klaus Vogel Lecture, which will be held in September 25, 2015, in the Vienna University of Economics and Business (see invitation here). I…
In many respects a multilateral tax treaty represents an utopian view of international tax law: a wide consensus among nation states to submit themselves to a common set of rules that govern the…
On August 12, 2015 the IRS released two final revenue procedures impacting the U.S. transfer pricing regime. Revenue Procedure 2015-40 concerns the protocols and procedures for requesting assistance…
Attacking Profit Shifting by Prof. Jeffery Kadet (Abstract) In recent years the financial press has turned increasing attention to MNCs that shift income to low taxed jurisdictions overseas in order…
Dr. Andrew P. Morriss is Dean & Anthony G. Buzbee Dean’s Endowed Chairholder, Texas A&M University School of Law; Drew Estes is a JD/MBA Candidate, Class of 2016, University of Alabama. Excerpted…
What is going on in the corporate tax world? In 2013 I predicted BEPS would be a success, at least based on the press release to be issued by OECD and G20 on January 1, 2016. I have always been a…
