The US Internal Revenue Service released final regulations on December 30 that provide that certain changes to debt instruments, derivative contracts, and other contracts to change the reference rate due to the discontinuation of the London Interbank Offered Rate (LIBOR) and other interbank offered rates will not result in a tax . . .
Leopoldo Parada, University of Leeds School of Law, discusses the lessons to be learned from the so-called “pandora papers” since their release by the International Consortium of Investigative Journalists (ICIJ) in October, such as the implications for the structuring of tax and financial laws going forward . . .
New York City Economist Dr. J. Harold McClure analyzes Australia’s Federal Court of Appeals ruling on December 17 in favor of the Australian Tax Office in Singapore Telecom Australia Investments Pty Ltd v. Commissioner of Taxation – a transfer pricing case involving intercompany interest payments in . . .
The ratio of tax revenues to GDP in OECD countries rose slightly in 2020 amid the Covid-19 pandemic, as nominal tax revenues generally fell but did so at a lower rate than countries’ GDPs, according to the OECD’s 2021 annual revenue statistics released December 6; corporate income tax revenues . . .
The US Tax Court will not reconsider its 2020 transfer pricing decision that increased Coca-Cola’s US taxable income by about USD 9 billion in a case involving the pricing of cross-border intercompany royalties; in an order dated October 26, the court denied Coca-Cola’s motion, stating it would be “futile” . . .
New York City Economist Dr. J. Harold McClure analyzes the Supreme Court of Canada’s November 26 decision upholding a taxpayer-favorable ruling in The Queen v. Alta Energy Luxembourg S.A.R.L., in which the legal issue revolved around charges of treaty shopping, but the appropriate valuation of . . .
The US House of Representatives today approved a modified version of President Biden’s Build Back Better bill – including corporate and international tax changes – following protracted debates on the revenue and economic impacts of the provisions; the Senate will take up the bill sometime after . . .
The automatic exchange of financial account information between countries is linked directly to at least EUR 3 billion in additional tax revenues; it also has contributed, through voluntary disclosure and other programs, to more than EUR 112 billion in additional tax revenues, according to a November 17 . . .
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