United States

Americas

Muddled goals, broad scope lead to unexpected costs of OECD tax agreement

April 20, 2022

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.

Americas

Biden’s tax reforms could leave US multinational corporations at a competitive disadvantage

April 13, 2022

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?

April 12, 2022

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

The Pillar Two model rules: a train wreck in the making

March 10, 2022

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.

Americas

A regulatory tax hike on US multinationals

February 28, 2022

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back Better agenda, which still has not yet made its way through the US Congress.