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HOMETax Notes International07/15/2024News Stories


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SLOVENIA SHOULD REDUCE HIGH LABOR TAX WEDGE, OECD SAYS


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ON THE COVER


DOES PILLAR 2 QUALIFY TRANSPARENT ENTITIES AND PES AS RESIDENTS UNDER TAX
TREATIES?

By Valentin Bendlinger


COMMENTARY & ANALYSIS


DOES PILLAR 2 QUALIFY TRANSPARENT ENTITIES AND PES AS RESIDENTS UNDER TAX
TREATIES?

By Valentin Bendlinger


EUROPEAN UNION YEAR IN REVIEW: A GRAB BAG OF DECISIONS

By Lee A. Sheppard


REASSERTING U.S. TAX LEADERSHIP, STARTING WITH AMOUNT B

By Mindy Herzfeld


UNLOCKING ARGENTINA’S RIGI INCENTIVES: A STRATEGIC GUIDE FOR GLOBAL INVESTORS

By Fausto Geremia and Sebastián de la Bouillerie


FDII DEDUCTION SUPPORTS SIGNIFICANT U.S. ECONOMIC ACTIVITY

By Brandon M. Pizzola and Hilary Gelfond-Gross


REPLACING THE PILLAR 2 UTPR WITH AN UNDERTAXED PAYMENTS RULE

By Thomas Horst


REVISING THE TRANSFER PRICING REGULATIONS' RELIABILITY PROVISIONS

By Ryan Finley


PUBLIC COUNTRY-BY-COUNTRY REPORTING IN THE UNITED KINGDOM

By Nana Ama Sarfo


POLICY PERSPECTIVES


HOW THE U.S. FOREIGN TAX CREDIT CAN RESCUE PILLAR 2

By Patrick Driessen
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FEATURED NEWS


TAX CRIME ROUNDUP: HUNTER BIDEN ACCUSER PLEADS GUILTY TO TAX EVASION

By Nathan J. Richman and Tyrah Burris
| 12/23/2024
Tax Notes’ Tax Crime Roundup covers notable recent charges, convictions, guilty
pleas, sentences, and court decisions in tax-related criminal cases.


FEATURED ANALYSIS


PUBLIC COUNTRY-BY-COUNTRY REPORTING IN THE UNITED KINGDOM

By Nana Ama Sarfo
| 12/23/2024
Nana Ama Sarfo discusses the U.K. Labour party's history of supporting public
country-by-country reporting and notes there's still space for the U.K. to
demonstrate leadership on the topic.


SPECIAL REPORTS


DOES PILLAR 2 QUALIFY TRANSPARENT ENTITIES AND PES AS RESIDENTS UNDER TAX
TREATIES?

By Valentin Bendlinger
| 12/19/2024
Valentin Bendlinger explains how the relationship between pillar 2 and tax
treaties remains unresolved, using the example of transparent entities and
permanent establishments, raising multiple open questions.


TAX NOTES TALK


MAKING PROGRESS: UPDATES ON THE OECD TAX REFORM PLAN

By Stephanie Soong and David D. Stewart
| December 19

Tax Notes chief correspondent Stephanie Soong recaps the latest updates from the
OECD’s two-pillar project and highlights what is expected from the organization
in 2025.


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