Tags » International Tax

There's No Avoiding Corporate Tax Avoidance

By: Kadmiel Perez*

Large corporations are inescapable in modern society. They have embedded their businesses into our lives with their products, entertainment, and advertising, and out of that labor they generate billions of dollars in revenue. 2,497 more words

European Union

Let slip the dogs of war

I have just emerged from a fascinating two-day conference in rain-soaked Lisbon. Despite the headline title, the real theme was inevitably the prospects for the Base Erosion and Profit Shifting project of the OECD, the rump of which is due to be approved by the G20 shortly. 617 more words

International Tax

BEPS, value creation and transparency

Over several decades and in step with the globalization of the economy, world-wide intra-group trade has grown exponentially. Transfer pricing rules, which are used for tax purposes, are concerned with determining the conditions, including the price, for transactions within a multi-national enterprise (MNE) group resulting in the allocation of profits to group companies in different countries. 725 more words

International Tax

IRS Releases Revised Information on the United States-Canada Income Tax Treaty

The U.S. Internal Revenue Service (“IRS”) has released revised Publication 597 (Rev. October 2015), “Information on the United States-Canada Income Tax Treaty” (the “Publication”). The 1980 United States-Canada income tax treaty was signed on 26 September 1980. 293 more words


Tax Treaty Briefing September 2015

Allan Cinnamon is the trainer for the Quorum training courses on International Tax Planning Part 1 and Part 2. 86 more words


Redefining the boundaries of International Taxation

In what may be regarded as the single-most collaborated cross-border tax reform, the final reports relating to the OECD project on base erosion and profit shifting (BEPS) were released by the OECD on 5 October 2015. 723 more words

International Tax

BEPS and the Indian outbound investor: are we ready for CFC Rules?

5 October 2015 was a red-letter day for the global tax community. The OECD released final reports on all 15 Action Plans of the Base Erosion and Profit Shifting (BEPS) project, which was undertaken at the behest of the G20. 788 more words

International Tax