GILTI

GILTI, Global minimum tax, Made in America Tax Plan, United States

(Osgoode Hall Law School)/ /Leave a comment

The inspiration for this post is “The Made In America Tax Plan” (https://home.treasury.gov/system/files/136/MadeInAmericaTaxPlan_Report.pdf) recently released by the U.S. Department of the Treasury to outline President Biden’s Administration’s outlook on taxation, notably in so far as the “internationalization” of taxpayers’ undertakings is concerned.  This is a much shorter version of and directly excerpted from comments I…

DST, EU law, GILTI, Made in America Tax Plan, Pillar I, Pillar II, United States

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Chiomenti)/ /Leave a comment

Raffaele Russo[1] “In those countries where income taxes are lower than in the United States, the ability to defer the payment of U.S. tax by retaining income in the subsidiary companies provides a tax advantage for companies operating through overseas subsidiaries that is not available to companies operating solely in the United States… The undesirability…

Effective Tax Rate, GILTI, IIR, OECD, Pillar II, United States

(Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

Welcome to the second tax post in the series of International Law Talk. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and experts in the field of International Arbitration, IP Law, International Tax Law and Competition Law. Here at Kluwer Tax Blog, we will…