In Notice 2004-19, the Treasury Department and the IRS abandoned proposals announced in Notice 98-5 (1998-1 C.B. 334), to require foreign tax credit planning structures to satisfy a broadly worded economic-profit test and, instead, announced various specific steps to combat abusive foreign tax credit planning
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The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process