As the US economy continues to sputter, it is perhaps not surprising that Congress and the administration have looked to change the country’s international tax rules to increase revenue. David Forst and Adam Halpern, partners at Fenwick & West, explain some of these changes, including legislative developments and new case law that will have implications for multinational corporations.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model