The report discusses the initial implementation of BEPS in the United States, United States interests, gains and losses in the context of BEPS, and an outlook of the role of the United States in the future international tax regime. The report was prepared on behalf of the United States IFA...

The article argues that the BEPS project has made only minimal progress in its work on the transfer pricing for intangibles, despite the prominence of the issue. More specifically, it achieved none but increased confusion and incoherence in the context of the specific rules for CCAs

This position paper provides possible solutions to the challenges presented to the international tax regime by the digital economy. It considers the option of installing a broad withholding mechanism based upon the base erosion principle both as a primary response to these challenges or in...

The objective of this contribution is to provide the OECD with a view to designing the final 2020 Report, the EU Institutions projecting an eventual legislative action and whatever States considering or (re)considering unilateral measures in the field of taxation of the digitalized economy with...

Tax regulation authors habitually infuse regulations with explanatory examples. These examples are viewed favorably by both the government that encourages their drafting and the taxpayers who regularly rely on such examples to assist them in dealing with the notoriously complex tax rules....

The Article demonstrates, based on publicly available data and using a variety of indicators that the most salient initiatives to promote inclusivity within the international tax regime (Country-by-Country Reporting, the Multilateral Instrument, and the Inclusive Framework) have at best done...

This Article proceeds as follows: Part I reviews the traditional U.S. international tax policy, followed by Part II that highlights the impact of the Tax Cuts and Jobs Creation Act of 2017 on such policy. Part III provides context to the proposals made by this Article with a discussion of the...

Unprecedented attention to aggressive international tax planning has shaken the earth under the most powerful players in the world of international tax policy design. The media exposure of what Bloomberg's calls “The Great Corporate Tax Dodge,” combined with the ever-growing discontent of...

The article argues that despite the fanfare around it, the outcome of the BEPS project is unlikely to be dramatic, at least in the short term. Beyond a period of increased legal uncertainty and aggressive enforcement by some countries, it expects little substantive change in tax treaties. The...