Noopur Trivedi and Jitesh Golani, international tax researchers, discuss how – out of the multiple design elements of the global minimum tax in the OECD/G20 July 1 statement – the adoption of “jurisdictional blending” for computation of effective tax rate, and consequent top-up tax, is one of the most pivotal . . .
The US Financial Accounting Standards Board should adopt in its standard-setting agenda a requirement for companies to report information in the notes to their financial statements on the disaggregation of country-by-country income tax, according to a September 22 letter signed by 63 organizations that . . .
In an August 26 letter, Congressman John Larson (D-Conn.) urged House Ways and Means Chairman Richard Neal (D-Mass.) to include in the “chairman’s mark” of the budget reconciliation bill a four-year delay in the upcoming requirement for companies to amortize research and development (R&D) expenditures . . .
New York City Economist Dr. J. Harold McClure analyzes the situation surrounding the IRS’s large transfer pricing adjustments for 2010–2015 involving the intercompany pricing between Amgen’s US parent and its Puerto Rican manufacturing affiliate, with issues seeming to mirror those in Medtronic’s . . .
Senate Finance Committee Chairman Ron Wyden (D-Ore.) on August 25 released draft legislation for international tax reform that would retain but modify key provisions of the Republicans’ 2017 tax law, including the global intangible low-taxed income (GILTI) provision, foreign-derived intangible income (FDII), and . . .
Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .
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