When the US Congress codified the long-standing common law doctrine known as economic substance, many tax practitioners were not shy about criticising the move, expressing concern about the effects of this new law on corporate tax planning. Erin Kelechava spoke to tax lawyers, professors, and policy experts and found out that a statute that was meant to clarify what an abusive transaction is may end up achieving the opposite result.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’