The attached letter includes concrete suggestions for the IRS Joint Strategic Emerging Issues Team to consider. The approaches suggested attack profit-shifting structures and have the potential to collect additional taxes avoided through aggressive and often sham uses of these structures.In...

This is a letter to the editor of Tax Notes Federal that highlights some changes to subsections (d) and (e) of section 954. These are the definitional rules for what is foreign base company sales income and foreign base company services income.I see this as something that was likely drafted by a...

This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.Much of the submission concerns sourcing and effectively...

On March 25, 2019, the FASB released Proposed Accounting Standards Update (Revised) concerning Income Taxes (Topic 740).There is a critical need to expand required disclosures for multinational groups (MNCs) under generally accepted accounting principles. Many MNCs carry material tax risks from...

By measuring base erosion only through certain related party outbound payments, the Tax Cuts and Jobs Act misses much of the profit shifting that has created the more than $2.6 trillion of overseas untaxed profits. This article shows how the base erosion provisions in the legislation could be...

This is a mid-2020 Update of my 2016 BEPS Primer article. This 2020 Update is in two parts. Part 1 focused on the initial two-year BEPS project and developments concerning it since the release of the October 5, 2015 Final Reports. This Part 2 focuses on Pillars One and Two of the currently...

This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.Much of the submission concerns sourcing and effectively...

With the OECD issuance in June 2018 of its final guidance on the profit split method, individual countries must determine how they might consider and apply the profit split method (PSM) going forward. The OECD guidance issued reflects a consensus view that included input from the very large...

This letter to the Treasury and the IRS is in response to Notice 2-43's request for recommendations for the 2-2 Priority Guidance Plan on tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. Many of...