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…
Last month, Dennis Weber started a debate on recent BEPS-related changes to European tax directives with his post on the General Anti-Abuse Rule in the Parent-Subsidiary. I would like to follow up on…
Haydon Perryman’s exclamation this month, in the form of the above title, underlies that the FATCA GIIN update as of August 2015 is that there is little to update in terms of new GIINs. From July…
In general terms, the application of anti-hybrid rules proposed by the OECD in Action 2 of the BEPS Project, with the aim of establishing a link between the tax treatment applicable to 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…
The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in…
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…
Dr. Andrew Morriss, Dean of Texas A&M University School of Law
The rapidly shifting world of international financial and tax regulation – from the OECD’s BEPS to FATCA – is reshaping the world. Many…
