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Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
Alex M. Parker, Capitol Counsel LLC, discusses why last year’s OECD-G20 global minimum tax agreement has revealed a scope much broader than most anticipated; provisions of the agreement, revealed in technical commentary released by the OECD in the past months, could affect everything from green energy incentives to affordable housing credits in the U.S.
Accounting
Americas
Americas
Americas
Americas
Accounting
Americas
Biden’s tax reforms could leave US multinational corporations at a competitive disadvantage
Kyle Pomerleau, American Enterprise Institute, warns that while the Biden Administration’s recently released 2023 budget—which includes additional reforms to the tax treatment of multinational corporations—is intended to further align the U.S. tax code with the OECD’s Pillar Two model rules and enhance the competitiveness of U.S. multinational corporations, they actually could leave U.S. companies at a competitive disadvantage.
Americas
Interest on inbound financing: is it arm’s length?
Annemarie Wilmore, Johnson Winter & Slattery, discusses the latest developments in the Australian case of Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation when the Australian Federal Court issued a further decision on March 22, including its consideration of whether consequential adjustments to the transfer pricing benefit should be made to take into account carryforward losses.
Americas
Americas
Americas
Americas
What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
Allen Tobin, CrossBorder Solutions, discusses the U.S. House of Representatives’ April 1 passage of legislation to decriminalize marijuana at the federal level; the legalization of cannabis has been a hot topic politically, and, if passed in the U.S. Senate, its potential impact on tax issues will be significant—especially for the research and development tax credit.
Americas
Americas
Accounting
Americas
Americas
Why Pillar Two should be abandoned
Allan Lanthier, a former advisor to the Canadian government, argues that when EU finance ministers next meet on April 5, they should abandon Pillar Two, which, he says, is a deeply flawed initiative that includes major changes on which countries had never previously agreed, including a new Domestic Minimum Top-Up tax and a significant rewrite of the Undertaxed Payment Rule.
Americas
Accounting
Americas
Americas
Implications of US Sixth Circuit Court’s reaffirmation that Whirlpool must pay taxes on US $45 million in income
Jack Taylor, University of Minho, discusses the long-term implications of the U.S. Court of Appeals for the Sixth Circuit’s March 2 reaffirmation of the previous December 2021 decision in Whirlpool v. Commissioner of Internal Revenue, which held that Whirpool must pay taxes on USD 45 million in income.
Americas
Africa
Accounting
Americas
Americas
Americas
The Pillar Two model rules: a train wreck in the making
Allan Lanthier, a former advisor to the Canadian government, warns it’s time to hit the emergency brake on the OECD’s model rules for Pillar Two; while close to 140 countries agreed to the October 2021 framework, they didn’t agree to these new model rules, which introduce a lot of uncertainty and complexity.
Accounting
Americas
Mexican tax reform 2022 – key topics to review from an international fiscal perspective
Arturo Treviño Villarreal, Fratelli Consultores, discusses several changes to Mexico’s 2022 tax reform that are having significant implications for both domestic taxpayers and nonresidents, triggering an array of tax reporting and compliance obligations that could impact cross-border transactions of MNEs operating in the country.
Americas
Americas
Americas
Americas
