Introduction Throughout my professional life, I have worked with international tax law. Consequently, I have witnessed various trends and tendencies for more than a quarter of a century. The period during which I’ve been involved in tax law in my view represents a golden age for the discipline. Significant developments have occurred. During my student…
1. Background 1.1 An overview of current tax proposals The Omnibus Bill (Ley de Bases y Puntos de Partida para la Libertad de los Argentinos, the Bill) is a multi-purpose, comprehensive legislative proposal aimed at funneling and materializing several main objectives pursued by President Milei’s administration, concerning the restructuring of the public sector and the…
Just two weeks ago on 8 October 2021, 136 of 140 member countries of the OECD/G20 Inclusive Framework agreed on a global tax deal that also features the GloBE international effective minimum tax (the so-called Pillar 2 of their work program). The G20 finance ministers backed the deal in their subsequent meeting, too. The agreement…
On April 5, 2021, U.S. Treasury Secretary Janet YELLEN “grabbed the attention of the occupants of corner offices worldwide with a speech to the Chicago Council on Global Affairs. The headline was a call for countries to agree on a global minimum tax rate for large companies.” (The Economist, April 8, 2021). In the slipstream,…
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…
