Remote Control Even in natural resource extraction, of all places, issues with remote and temporary workers can confound traditional tax principles.
The Remaining Pillar Two Headaches Pillar Two advocates are still hoping that Congress can bring the U.S. into the system and relieve worries about increased foreign taxation of U.S. businesses. But Congress may only be able to do so much.
Safe Spaces Safe harbors could ease some of the pain from the OECD's new minimum tax, but here's why they won't be a panacea for taxpayers.
The Unfairness of a "Fair Share" Companies and wealthy individuals are often accused of shirking their responsibility to pay a "fair share" of taxes. Here's why tax experts tend to hate that characterization.
Racing to the Top If the new global minimum tax truly dampens tax competition, how will jurisdictions respond? There are already anecdotes that they're looking outside the tax realm for competitive advantages.
Luck of the Irish Why is the Emerald Isle doing so well in the post-BEPS world, and what does that mean for the overall global tax landscape?
Is the U.S. Hand at the OECD Weakening? An official at the U.S. Treasury Department says that so long as the U.S. remains out of compliance on the OECD's Pillar Two, its ability to demand changes could be diminished.
Why the U.N. Vote on Taxes Matters The U.N. voted to take on a greater role in taxation–an escalation in its long-simmering rivalry with the Organization for Economic Cooperation and Development. Even though the U.N. plans for a global tax body seem far-fetched, it's already changing global tax dynamics.
Indebted to Yourself Intercompany debt can be one of the most vexing issues in international taxation, even after recent reforms. Why this issue could come to a head in 2025.
Ideal Tax Credits Under the Global Minimum Tax Even after the OECD's new global minimum tax, countries will try to lure companies with tax incentives. But what will those new breaks look like?
Withhold Your Horses! Withholding taxes could be the next big holdup for the OECD's 140-country agreement on digital taxes. Here's what this means for the overall project going forward.
The Fight for 15 (Percent) Many critics claim the OECD's 15% global minimum tax rate is too low. Here's how they got to that figure, and what it means for the overall project.
Taxes and Tail-ends The latest OECD Pillar One Amount A designs attempt to tilt the balance towards developing countries in a potentially paradigm-shifting way.
The Imperfect Global Tax Answer There are a lot of outstanding questions on the OECD's global minimum tax plan, but they don't necessarily all need answers.
Never Surrender? Is the Biden administration ceding tax authority to the OECD? Perhaps–but there’s a century’s worth of context.
Amount B and Digital Goods Whether or not the OECD's promising "Amount B" project for developing countries should delve into the digital realm is shaping up to be one of the key disagreements between tax authorities and taxpayers.
The U.S. and Pillar Two, in 2025 and Beyond If the U.S. ever complies with the OECD's global minimum tax plan, what will that compliance look like? It's a surprisingly tricky question that could dramatically influence the project's future.
Finding Canadian Online Users The Internet runs on non-paying users--how should the global tax system account for them? Canada's controversial digital services tax has an interest approach that could have broader implications.
The OECD and the Global South Why the OECD's global minimum tax could lead to a revenue surge for developing countries, despite their growing skepticism and opposition.
The Stock and Substance of the OECD Min Tax While the tax world has focused on credits, the calculation for the OECD global minimum tax's substance-based carveout, including details like the measurement of stock options, could be crucial for taxpayers.
Bidenomics' Tax Conflicts President Biden sees "Bidenomics" as a winning economic message–here are some of the questions it raises about tax policy.
Accounting for Amount B A promising OECD initiative seeks to simplify routine tax matters to give some relief to beleaguered cash-strapped tax authorities. But just because the issues aren't sexy doesn't mean they won't be complicated.
The Sixth Sense (of Commodity Prices) Explaining the "sixth method" for pricing commodities, what it means for the global tax system, and why taxes for mining and other minerals can be so difficult.
Formula Won? The OECD's under-taxed profits rule remains the focus of an angry political debate--but its formulary aspects aren't getting much notice.
A Path Forward for the OECD? The OECD grants the U.S. a two-year reprieve--and maybe the pieces for a larger fix.
