United States
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line
A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices
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Sponsored by EY Asia-PacificThe indicators point in one direction: an increase in tax controversy, as authorities’ resources are ploughed into increased scrutiny. Luis Coronado of EY explains why, and suggests what tactics businesses should be adopting. -
Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US review recent Internal Revenue Service enforcement efforts regarding foreign corporations’ US income tax returns, and discuss the waiver process for taxpayers with untimely returns.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the inclusion of updates to the US Internal Revenue Service’s (IRS) mutual agreement procedure (MAP) and advance pricing agreement (APA) revenue procedures in its priority guidance plan, and consider how successor guidance could further improve the MAP and APA programmes.
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