Transfer Pricing in Brazil: Towards Convergence with the OECD Standard

Spain’s Additional Wealth Tax on Taxpayers With $2.9 Million in Assets

How to Properly Land Foreign Gifts?

Will the U.S. Fully Implement OECD Tax?

The Biden administration wanted to enact the “Build Back Better Act” (BBB). The goal was to be OECD-compliant on its 15% global corporate minimum tax and strengthen GILTI.

BBB never came to a vote in the Senate until last week.

On July 27, a deal was reached to scale down BBB – the “Inflation Reduction Act of 2022” (IRA).

IRA includes the 15% CMT but does not include any GILTI changes.

Senators Manchin and Schumer pondered not putting US corporations at a competitive disadvantage and damage the US economy.

Estate Planning for Global Families

Estate Planning Journal, Thomson Reuters

March 2021

International Tax Journal / Thomson Reuters, August 2019
Article: International Tax Arbitration: Global Tax Competition: Corporate vs. State

International Tax Journal / Thomson Reuters, March 2019 Article: International Tax Arbitration: Challenges and Opportunities

Estudos de Tributação Internacional, 2019 (International Taxation Studies) Co-author Editor: Lumen Juris ISBN: 978-85-519-1577-6