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The OECD’s Pillar Two Model Rules Have Arrived

OECD - December 22 2021 On December 20, 2021, the OECD released the Model Rules for Pillar Two or the “Global Anti-Base Erosion” (GloBE) Rules. The GloBE Rules are the…

Jenny A. Austin, Michael Lebovitz

Milestone Agreement Reached by 136 Countries on Significant Changes to the Global Tax Landscape

OECD - October 12 2021 On October 8, 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) announced that 136 countries have agreed on a two-pillar…

Jenny A. Austin, Lucas Giardelli, Kenneth Klein, Michael Lebovitz, Amit S. Neuman, Jason M. Osborn

Do Recent Changes to IRS Appeals Procedure for Large US Taxpayers Fully Address Their Concerns About Its Independence?

USA - September 17 2021 The Independent Office of Appeals (“Appeals”) is one of the few venues available to taxpayers to resolve disputes with the US Internal…

Brian W. Kittle, May Y. Chow, William G. McGarrity

Standard of Review in Transfer Pricing Litigation

USA - August 31 2021 A recent Tax Notes article analyzes the “standard of review” that the Tax Court will apply to the IRS’s transfer pricing adjustments. In transfer…

John T. Hildy, Anthony D. Pastore

No Secrets are Safe in an Era of Global Tax Information Exchange

Global - August 2 2021 Many taxpayers are familiar with information document requests where taxpayers are notified that taxing authorities are inquiring into certain…

Jenny A. Austin