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base erosion

Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System

October 15, 2021 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. Pillar One: a new taxing right in the digital worldPillar Two: a global minimum tax rate of 15%The road(blocks) ahead Read the full advisory here. [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: base erosion, base erosion and profit shifting, BEPS, Corporate tax rate, digitalization, Income Inclusion Rule, international, MLC, MNE, MNEs, OECD, Rome, Subject to Tax Rule, transfer pricing, Undertaxed Payment Rule, Washington D.C.

The Other Green Book: Treasury Explains Administration’s Tax Proposals

June 16, 2021 By Edward Tanenbaum, Heather Ripley and April McLeod

With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the significant changes to the Tax Code the Administration won’t find easy to navigate through a Congress that features the slimmest of majorities. Major revisions to the Tax Cuts and Jobs Act of 2017Tighter rein on interest deductions and inversionsRepealing BEAT and FDII, creating a new SHIELD against base erosion Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: base erosion, BEAT, Biden Administration, CFC, crypto, FDII, global minimum tax rate, Green Book, SHIELD, tax reform, Treasury

The BEAT (Still) Goes On – New Final and Proposed BEAT Regulations

January 17, 2020 By Richard Slowinski and Stefanie Kavanagh

Earlier this week, our International Tax Group analyzed some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax.

Clarifications about base erosion payments
Clarifications about aggregate groups
Election to waive deductions

Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: base erosion, BEAT, IRS, Section 59A, Tax Cuts and Jobs Act, Treasury

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