LexisNexis® Legal Newsroom
Obama's Rate Cut: How Low Can You Go?

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 rate from 35% to 28%. He's vague on the details...

OECD Praises Itself Through G20 For Progress on Tax Evasion - But Is It Praiseworthy?

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 the G20 lacks an independent infrastructure in...

Managing the Competent Authority Process for U.S.-Based Multinational Enterprises

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 very large tax adjustments upon multinational enterprises...

A New Proposal to Promote American Manufacturing

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 15 presentation at a conference on taxation and...

'Legal Enemies of the State'!

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. In Tax Notes this week I wrote about abusive transfer...

OECD Doesn't Want Politics to Interfere with Tax Policy

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 my first read of the 91-page document I believed...

Can the OECD Be Trusted on Base Erosion?

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 and profit shifting (commonly called BEPS)....

Intercompany Agreements for U.S.-Based Multinational Enterprises

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) of the Transfer Pricing Guidelines for Multinational...