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...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...

The Baucus Discussion Draft on international tax reform includes a mechanism for taxing the accumulated foreign earnings of controlled foreign corporations as of the effective date that a new system for taxing foreign earnings is effective.This letter suggests changes to make this aspect of the...

I am commenting on the form that International Tax Reform should take. In brief, the territorial system strongly lobbied for by the U.S.-based multinational corporations (MNCs) standing to benefit from such a system is not what is best for our country or our society. It is bad tax policy in...

This letter to the Treasury and the IRS is in response to Notice 2019-30's request for recommendations for the 2019-2020 Priority Guidance Plan on tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance....

This is a letter to the editor of Tax Notes Federal that highlights some changes to subsections (d) and (e) of section 954. These are the definitional rules for what is foreign base company sales income and foreign base company services income.I see this as something that was likely drafted by a...

This short piece was prepared for a Tax Notes Federal Global Roundtable on “Displaced Employees and COVID-19: The New Tax Obligations”. It points out that the continued success of many U.S.-headquartered MNEs to continue their supply chains and their conduct of internet-based businesses...