This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.Much of the submission concerns sourcing and effectively...

On March 25, 2019, the FASB released Proposed Accounting Standards Update (Revised) concerning Income Taxes (Topic 740).There is a critical need to expand required disclosures for multinational groups (MNCs) under generally accepted accounting principles. Many MNCs carry material tax risks from...

By measuring base erosion only through certain related party outbound payments, the Tax Cuts and Jobs Act misses much of the profit shifting that has created the more than $2.6 trillion of overseas untaxed profits. This article shows how the base erosion provisions in the legislation could be...

This is a mid-2020 Update of my 2016 BEPS Primer article. This 2020 Update is in two parts. Part 1 focused on the initial two-year BEPS project and developments concerning it since the release of the October 5, 2015 Final Reports. This Part 2 focuses on Pillars One and Two of the currently...

This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.Much of the submission concerns sourcing and effectively...

With the OECD issuance in June 2018 of its final guidance on the profit split method, individual countries must determine how they might consider and apply the profit split method (PSM) going forward. The OECD guidance issued reflects a consensus view that included input from the very large...

This letter to the Treasury and the IRS is in response to Notice 2-43's request for recommendations for the 2-2 Priority Guidance Plan on tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. Many of...

This letter responds to the request in Notice 2017-28 for public comment on recommendations for items that should be included on the 2017-2018 Priority Guidance Plan. Recommendations in this letter cover various treaty abuse situations

The authors discuss changes to the scope of the U.K. royalty withholding tax announced in the 2016 U.K. budget, which, along with the new diverted profits tax, could cause significant increases in U.K. tax paid by multinationals. As will be seen from the example set out in the article, the U.K....