Taxation of Multinational Businesses

New Research Shows Major Changes for U.S. Companies Earning Profits from Ireland

Carve-ins and Carve-outs: Open Questions for Global Tax Reform

Two Important Issues that Must Be Resolved in “Global Tax Reform”

GILTI by Country Is Not as Simple as it Seems

Treasury’s Latest Pillar 1 Proposal: A Strategy to Split the Riches or Give Away the Store?

TCJA Is Not GILTI of Offshoring

How GILTI Are U.S. Industries?

Can GILTI and the GloBE be Harmonized in a Biden Administration?

U.S. Cross-border Tax Reform and the Cautionary Tale of GILTI

An “Interest”ing Tax Hike in the COVID-19 Relief Proposal

The European Commission and the Taxation of the Digital Economy

Tax Foundation Response to OECD Public Consultation Document: Reports on the Pillar One and Pillar Two Blueprints

Comparing Europe’s Tax Systems: International Tax Rules

Two Roads Diverge in the OECD’s Impact Assessment

Pillars, Blueprints, an Impact Assessment, and Construction Delays

Thin-Cap Rules in Europe

Challenges for Transfer Pricing in an Economic Downturn

Summary of the OECD’s Impact Assessment on Pillar 1 and Pillar 2

How Controlled Foreign Corporation Rules Look Around the World: Colombia and a Perspective of Latin America

How Controlled Foreign Corporation Rules Look Around the World: Germany