The attached letter includes concrete suggestions for the IRS Joint Strategic Emerging Issues Team to consider. The approaches suggested attack profit-shifting structures and have the potential to collect additional taxes avoided through aggressive and often sham uses of these structures.In...

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...