Tax Law

Recent Posts

Intercompany Agreements for U.S.-Based Multinational Enterprises
Posted on 30 Dec 2014 by LexisNexis Tax Law Community Staff

On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its final guidance on transfer pricing documentation and country-by-country (CbC) reporting. Developed as a replacement for the existing Chapter V (Documentation... Read More

A New Proposal to Promote American Manufacturing
Posted on 26 Mar 2013 by Martin A. Sullivan

In recent years U.S. multinationals have restructured themselves in a manner that allows them to greatly reduce their worldwide tax bill. This restructuring has been described in detail by the OECD andil and by the Joint Committee on Taxation . In a March... Read More

Can the OECD Be Trusted on Base Erosion?
Posted on 25 Jun 2013 by TaxAnalysts®

by Jeremy Scott After years of creating rules that allow multinational corporations to shift profits and income to whatever jurisdiction they like, the OECD is now very concerned about base erosion. In fact, it is drafting a major report on base erosion... Read More

OECD Doesn't Want Politics to Interfere with Tax Policy
Posted on 17 Apr 2013 by Martin A. Sullivan

I was wrong. I thought that The Organisation for Economic Co-operation and Development (OECD) had shrugged off its cautious, conservative tendencies with the issuance of its February 12 report entitled "Base Erosion and Profit Shifting ." After... Read More

OECD Praises Itself Through G20 For Progress on Tax Evasion - But Is It Praiseworthy?
Posted on 20 Jun 2012 by Allison Christians

In a recent post on its website, the OECD says that the G20 has reported that "steady progress is being made towards tackling tax evasion more effectively." In an article I wrote in 2010, I called the G20 a syndicator of OECD tax views , since... Read More

Managing the Competent Authority Process for U.S.-Based Multinational Enterprises
Posted on 13 Feb 2013 by LexisNexis Tax Law Community Staff

by Barry Shott, Richard Barrett and Elizabeth Sweigart * Under pressure to close revenue gaps and to address perceived aggressive tax positions related to the pricing of cross-border transactions, both the U.S. and foreign tax authorities are imposing... Read More

Obama's Rate Cut: How Low Can You Go?
Posted on 23 Feb 2012 by Robert Goulder

President Obama's newly released 'framework' for corporate tax reform envisions a significant rate cut for U.S. firms. You can read the details at the President's Framework for Business Tax Reform . His basic idea is to lower the statutory... Read More

'Legal Enemies of the State'!
Posted on 29 Mar 2013 by Christopher Bergin

How does that old Wall Street saying go? Bulls make money; Bears make money; Pigs get slaughtered. Bulls in this context are easily defined, and so are Bears. Money can be measured. But it seems to me that piggy behavior is in the eyes of the beholder... Read More

OECD Praises Itself Through G20 For Progress on Tax Evasion - But Is It Praiseworthy?
Posted on 20 Jun 2012 by Allison Christians

In a recent post on its website, the OECD says that the G20 has reported that "steady progress is being made towards tackling tax evasion more effectively." In an article I wrote in 2010, I called the G20 a syndicator of OECD tax views ,... Read More

Obama's Rate Cut: How Low Can You Go?
Posted on 23 Feb 2012 by Robert Goulder

President Obama's newly released 'framework' for corporate tax reform envisions a significant rate cut for U.S. firms. You can read the details at the President's Framework for Business Tax Reform . His basic idea is to lower the statutory... Read More