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.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap