Stock Buybacks and International Tax The Inflation Reduction Act disincentivizes stock buybacks--but it also may entangle legitimate crossborder transactions, even when they're unrelated to stock.
Is a Pillar Two Trade War Inevitable? Republicans have declared war on the OECD's global minimum tax--and in a few years they may be able to fight it.
Supreme Chaos Why the Supreme Court's decision to review a key TCJA provision could upend the international tax system at a fundamental level.
The R&D Credit and the OECD Global Min Tax Why the top U.S. business tax credit isn't compatible with the OECD plan, and why this is creating a political firestorm at home.
Incredible Intangibles An interesting new paper sheds light on just how much of our global tax system is make-believe.
Was the UTPR Necessary? It's the rule that everyone loves to hate--does the OECD really need it to hold its global minimum tax together?
Intangibles in the Outback Corporate groups claim new Australian anti-abuse rules go too far. What it says about the difficulties in designing taxes to hit intangible assets, the source of so many tax problems.
QDMTTs, CFCs, and Potential Complications Practitioners and taxpayers have flagged yet another potential glitch in how the OECD's new global minimum tax could interact with the U.S. system.
Aussie Openness Australia is pushing for full public country-by-country reporting in tax, which would make it a trailblazer in the global tax world. What this could mean for the entire system.
The OECD in the Spotlight The 15% global minimum tax has thrust the Organization for Economic Cooperation and Development into the public eye--and political cross-hairs. How will it affect the organization's work going forward?
Refundability and Transferability There's a narrow pathway to keep the OECD's global minimum tax from colliding into the Inflation Reduction Act's green energy spending--has it already closed?
Yes We CAMT Republicans haven't put Biden's 15% corporate minimum tax in their sights yet. Is it just a matter of time, or does it actually have some bipartisan appeal?
At a Loss Minimum taxes are meant to capture income from profitable companies that somehow escape significant tax liability. But when those companies see uneven earnings, or loss years in particular entities, trouble can arise.
The OECD and Climate Change The Organization for Economic Cooperation and Development tackled international tax avoidance. Are they ready to take on the biggest existential threat of our times?
The Qualified Domestic Minimum Top-Up Tax--Corporate Taxpayers' New Nightmare, or Pillar Two's Missing Piece? The QDMTT is likely to be the operative provision of the OECD's global minimum tax, that most companies will actually have to deal with. It has the potential to be a huge headache, but a safe harbor could ease administration.
The Long Road to Tax Transparency A new proposal for public tax reporting is being considered. It's just the latest in a long campaign that, despite setbacks, never seems to go away.
All the Tax in China U.S. critics say that the 15% global minimum tax will be a windfall for China. That may come as a surprise to the Chinese.
Cliff-Diving Congress will face some big choices about taxes in 2025. Will this be a chance to pass the OECD tax agreement?
Why There Won't Be a Global Min Tax Treaty Taxpayers want a new multilateral treaty to enforce the OECD's global minimum tax, which is a longshot. But the request reveals how much the project has evolved from its (relatively) simpler beginnings.
The Big Picture in International Taxes There used to be a clearer picture of what the problems were in the global tax system. But today, we're still struggling to evaluate whether the solutions we've implemented are working.
Crumbs in a Blender The OECD's new "blended CFC regime" definition isn't all that U.S. taxpayers were hoping for, but it could give them some limited relief. In international politics, that's not nothing.
Green Energy and the OECD Tax Pact Will the OECD's global minimum tax hit the Inflation Reduction Act's green energy tax credits? It seemed like it was taken care of, but the latest guidance raises this possibility.
The Potentially Insurmountable Hurdles to Wealth Taxation in America International tax transparency may make a wealth tax more feasible today than in the past. But in the U.S., the concept faces political and legal challenges that could prove fatal.
Can We Really End the Race to the Bottom? Critics claim that the OECD's new global minimum tax won't truly end tax competition between nations. But is that really possible--or the right goal?
UTPR in the Air: Making Sense of the OECD's Most Controversial New Rule How the OECD's new enforcement rule upends the traditional principles of global taxation.
