Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation…
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)…
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’…
In a 207 page opinion the Tax Court ruled March 23, 2017 that the IRS’s adjustment with respect to Amazon.Inc's transfer pricing buy-in payment for an intragroup cost sharing agreement (CSA) is…
