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Germany signed bilateral tax treaties (the "New Treaties") with Luxembourg and the Netherlands on April 12 and April 23, 2012, respectively; the New Treaties replace former treaties (1958/73/09 and 1953/80/91/04, respectively).

On March 18, President Obama signed the Hiring Incentives to Restore Employment Act (H.R. 2847) (the "Act"), which includes several unrelated revenue raising provisions affecting foreign entities and individuals with certain foreign assets that were originally proposed as part of the Foreign Account Tax Compliance Act of 2009.

The Obama Administration recently unveiled initiatives to reform international tax laws which, if enacted, could reduce U.S.-based multinational companies' ability to compete with certain foreign companies.

The European Commission has published its proposal for a Directive to implement the OECD Pillar Two Global Anti-Base Erosion rules (the "OECD GloBE Model Rules").

The U.S. enters into bilateral investment treaties ("B.I.T.'s") to protect and promote foreign investment.

You are tax director of a multinational corporate group sitting in your office in New York. It is late Friday and, after a difficult week (like every other week), you are looking forward to some time off at the beach.

Last week, the California Court of Appeal in Apple Inc. v. Franchise Tax Board rejected Apple's claim for preferential ordering for dividends paid by foreign subsidiaries.

The U.S. Internal Revenue Service has posted draft versions of revised Form W-8BEN.

Because of travel restrictions, such as canceled flights and stay-at-home orders, the COVID-19 pandemic may have significantly limited a nonresident alien's ability to leave the United States.

In ancient Rome, a college of "augurs" would predict the future by observing the flight patterns of birds, examining the entrails of animal sacrifices, or interpreting natural phenomena. While perhaps less colorful, ...

The United States Internal Revenue Service (IRS) has issued new guidance that provides reassurance regarding the application of U.S. income tax treaties to widely used cross-border investment structures...

Peter Barnes co-wrote the May 22, 2023 letter "No Time for Waiting" for Tax Notes Today International. Below is the entire letter. Please visit this link to view the letter as it appears in Tax Notes Today International.

The O.E.C.D. announced on January 31, 2020, that its policy development efforts under Pillar One, related to the taxation of the digital economy, will move forward using the non-consensus...

While the Speaker drama unfolds and we find ourselves in the middle of the third week of a paralyzed House, Tax Take turns its attention to some noteworthy international tax developments.

Navigating the U.S. tax system is a critical aspect of doing business in the United States. Unlike other countries with a single national tax system, the U.S. has a multi-layered structure that includes federal...

The Treasury Department has issued proposed regulations fundamentally changing how U.S. shareholders calculate their pro rata share of controlled foreign corporation income when ownership interests vary throughout the year. These regulations implement amendments from the One Big Beautiful Bill Act, introducing daily proration methodologies, mandatory year-end closings for status changes, and new elective provisions for significant ownership variances.

On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of "shell" entities for tax purposes.

Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates.