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Under current EU law, taxation is a prerogative of the Member States, which is not subject to EU harmonisation.

At an open meeting of the SEC on December 3 at which it took action on rulemaking proposals aimed at late trading, market timing and selective portfolio disclosure, SEC Chairman William Donaldson outlined the SEC’s mutual fund regulatory agenda for the coming months. In the remainder of December, the SEC will consider (a) a proposal regarding better disclosure of breakpoint discount opportunities and (b) a concept release on disclosure of portfolio transaction costs.

Since President Trump took office in January of 2017, he has shown his desire to follow through with trade policies that were a central part of his campaign

The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) that provides helpful guidance regarding the application of the branch profits tax in connection with reverse foreign hybrid entities and U.S. income tax treaties with foreign countries.

Financial institutions are facing an increasingly interconnected global financial system, where financial transparency has emerged as a critical element of fiscal systems worldwide...

The client, a leading artificial intelligence software developer, has a Global Capability Center focused on Research and Development in India, monitored by the USA headquarters.

The U.S. Court of Appeals for the Fifth Circuit recently overturned the U.S. Tax Court in a case that could have created significant additional hurdles for taxpayers electing to create an account receivable under Rev. Proc. 99-32.

This article focuses on some of the often overlooked allocation opportunities and the hidden tax liabilities that are important to understand when a deal is being negotiated and priced. Many times, if these issues are not addressed prior to closing, the opportunities are lost.

As discussed in prior blog posts, Amount A is a proposed new taxing right over a share of residual profit of MNE groups that fall within its defined scope.

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform.

The OECD's recent recommendations with respect to transfer pricing documentation and country-by-country reporting may have the most significant impact on multinational enterprises of all of the OECD's BEPS proposals.

In today's global tax environment, transfer pricing has become a critical focus for tax authorities. With multinational companies operating across multiple jurisdictions...

Both combined reporting and 482 adjustments have had a renaissance in the past decade.

OBBBA restores 100% bonus depreciation and R&D expensing — boosting cash flow potential.

The IRS does not require any taxpayer to develop a transfer pricing study.

At a Washington tax conference on May 20, Treasury Assistant Secretary for Tax Policy Kenneth Kies reportedly signaled that anti-stacking regulations targeting Code §1202 qualified small business stock (“Q.S.B.S.”) are likely forthcoming.

Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the OECD since 2015.