When individuals have questions about Federal benefits, services, and legal rules, they are increasingly seeking help from government chatbots, virtual assistants, and other automated tools. Current forms of automated legal guidance platforms include the U.S. Citizenship and Immigration...

The European Union’s new Foreign Subsidies Regulation will lead to particular challenges in the tax domain. While the final version of the FSR now contains clear links to state aid, the differences are all the more noticeable. Third country tax measures that benefit group financing or equity...

Defined value clauses used to value nonmarketable family limited partnership (FLP) interests create valuation distortions and other public policy issues. This paper describes these abuses and proposes the employment of restrictions similar to those applied to pecuniary formula marital deduction...

Corporations and their shareholders have always sought opportunities to avoid entity- and shareholder-level tax liabilities under the U.S. corporate tax system. In response to the tax shelter boom of the late 1990s, Congress adopted what can be described as an “activity-based” approach to...

The Court’s judgment in Société Générale reinforces the established case law that EU law neither prohibits juridical double taxation as such nor does it put an obligation on the residence Member State to prevent the disadvantages which could arise from the exercise of competence thus...

This chapter focuses on addressing the prospective compatibility of the proposed Pillar Two rules with EU primary law and, in particular, the fundamental freedoms. In this respect, the authors observed that, as the Pillar Two package is a composite one, a distinction would need to be made...

The draft for a CCCTB Directive in the EU includes the suggestion for an apportionment formula which allocates taxable profits to group member corporations and to the respective Member States. The draft directive delegates the right to define one apportionment factor, the term ‘Employee’ to...

The reform process for the indirect taxation regime in India has been ongoing for some time, with the prevailing view being that simplification of tax regime and a principle-laden approach was an essential concomitant in the outlook of a developed nation. Much debate has ensued and during the...

In a recent decision of the Supreme Court in "Larsen & Toubro Ltd." has put to rest the dispute relating to the correctness of the "K. Raheja Development Corporation" and the distinction between a contract of sale and a works contract. This decision seeks to settle, after revisiting the...

In its decision in the case of Lisboagás (C-256/14) the European Court of Justice (‘ECJ') adverted to the issue whether other taxes paid by the supplier and collected from the receiver on actual basis are required to be added to determine the taxable value for VAT purposes. The ECJ in this...