For months, Congress promoted the tax reform effort as being focused on simplifying the outdated and complex 1986 Tax Code. Tax reform, culminating in H.R. 1, did no such thing, at least where it applies to multinational US corporations. Nowhere is this more apparent than in section 951A, the tax on global intangible low-taxed income, or ‘GILTI’. Erik Christenson, partner at Baker McKenzie, and Monte Silver, senior counsel at Eitan, Mehulal & Sadot explain.
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Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
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Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general