Alex M. Parker

I've covered taxes for 10 years at Bloomberg Tax and Law360. Ex-newspaper hack. Native Hoosier and Oberlin grad.

It's an Amount B World

While the OECD's Amount A flounders, Amount B is already having an impact on international taxes. But it's biggest influence could be as a ad-hoc, informal part of the system.

Retaliatory Strikes

Republicans are eager to push back against the OECD's global minimum tax if and when they have power--but they'll have to chose their tool carefully.

BONUS CONTENT: Foreign Tax Credits

Looking into the history of foreign tax credits, first passed by the U.S. in 1918. A post for paying subscribers.

Don't Do the (Tax) Time Warp Again

As in 2017, Congress faces a major overhaul of the tax code in the upcoming year. But if lawmakers think offshore cash can help cover the costs, like with the TCJA, they could be in for a shock.

BONUS CONTENT: Social Media and Taxes

This is a bonus post for paying subscribers. Sign up here for an Emperor Subscription to get full access, including past interviews and extra content. Maybe a decade ago, people used to joke that no one uses LinkedIn. Now, it’s hard to imagine life without it. Before social media,

Can the OECD Make a Fool-Proof Pillar Two Safe Harbor?

The OECD is trying to stamp out abuse of a Pillar Two safe harbor through hybrid arrangements--and it's capturing a lot of innocent structures, according to critics.

The Supreme Court, Executive Deference, and International Taxes

The Supreme Court is pulling back executive branch authority, but it's unclear how much this could affect international tax rules.

BONUS CONTENT: Harmful Tax Practices

This is a bonus post for paying subscribers. Sign up here for an Emperor Subscription to get full access, including past interviews and extra content. One of the key principles of the international tax system is that everyone is supposed to tend their own garden. Basic transfer pricing gives nations

The R&D Sticking Point

No amount of political or diplomatic fine-tuning can overcome the U.S./OECD disagreement on the valuable R&D tax credit. Some tougher decisions will have to be made.

INTERVIEW: Rasmus Corlin Christensen

Rasmus Christensen is a political economist at the Copenhagen Business School, who focuses on the international political economy and international taxation. He has written several papers about global tax governance and how developing countries are represented in negotiations over tax policy. This includes the recent initiative at the United Nations

An Economic-Like Substance

With a new interpretation of the economic substance doctrine, the courts may have given the IRS a powerful new tool to enforce the law--or further complicate it.

INTERVIEW: David Gamage

David Gamage is a professor of tax law and policy at the University of Missouri School of Law. He previously taught at Indiana University, and also served as special counsel to the U.S. Treasury Department. Last year, he co-authored an amicus brief in support of the government in Moore

Can the OECD Play the Trump Card?

A second Trump administration looks likelier than ever. His election could throw the OECD's Pillar Two project into disarray--or maybe give it the kick-start it needs?

BONUS CONTENT: Corporate Inversions

Can corporations be patriotic? They (or their spokespeople) would surely claim so. But as immaterial creations of law, can they really feel that deep welling of pride and civic responsibility that we associate with patriotism? And if they can be patriotic, can they be unpatriotic as well? That’s an

Surviving the Cliff

In 2025, Congress will look at overhauling the entire tax code. But the international portion could see fewer changes than the rest.

The "Exponential" Pillar Two Compliance Avalanche

Companies say that the 15% global minimum tax will impose monumental compliance costs--but not much in new taxes.

INTERVIEW: Shuting Pomerleau

I talk with Shuting Pomerleau, the deputy director of climate policy at the Niskanen Center, about carbon taxes, fiscal policy and international trade.

Implicit Support Group

A recent IRS memo states that it can lower an entity's credit rating--and the interest it can pay on an intercompany loan--due to its membership in a larger corporate group. Not everyone agrees.

BONUS CONTENT: Digital Taxes and the People Principle

There’s a basic mantra in the news business that any story, no matter how esoteric or technical, is ultimately about people. If you can’t figure out the human drama in your assignment—or how the issue you’re covering matters to the humans who are reading it—that’

Giving Back

The OECD rules will try to prohibit jurisdictions from giving back the money they raise through a new global minimum tax--but how it will work remains vague.

INTERVIEW: Anne Gordon

Anne Gordon is vice president for international tax policy at the National Foreign Trade Council, a business association which advocates for an "open, rules-based global economy." She previously served as chief tax counsel for Senators Rob Portman and Todd Young. We spoke on May 22. There's

Tax and Trade

If Pillar One fails, the U.S. could look at tariffs as the latest tool to defuse digital services taxes. It would be the latest example of the tax and trade spheres merging.

BONUS CONTENT: The Destination-Based Cash-Flow Tax

Some background on the transformative idea that took the U.S. tax world by storm in 2017, and then ended just as quickly.

The OECD's New Role in Global Taxes

A rushed Ireland order at the end of 2023 demonstrates the OECD's new power to set national tax laws.

FDII Sense

While massive tax agreements have everyone's attention, countries may be getting more aggressive about what they see as violations of the existing rules. One example is the TCJA's valuable deduction for intangible exports.