‘Transparency’ is the latest term of art that has emerged from the OECD’s Action Plan with respect to its base erosion and profit shifting (BEPS) initiatives. But the obvious question that has consciously been ignored in the public domain is: where are the matching transparencies regarding determination of tax risks and identification of substantive issues by tax authorities upon commencement and conduct of an audit?
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The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
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