The US Supreme Court’s decision in Mayo earlier this year caught the attention of tax professionals. George Hani and Alan Horowitz of Miller & Chevalier, Washington, DC, argue that the full impact of the case will depend on the outcome of a new case addressing whether deference is owed to a more aggressive effort by the IRS to issue regulations with retroactive effect.
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort