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Transfer Pricing in Brazil: Towards Convergence with the OECD Standard
Spain’s Additional Wealth Tax on Taxpayers With $2.9 Million in Assets
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, 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
International Tax Journal / Thomson Reuters, August 2019
Article: International Tax Arbitration: Global Tax Competition: Corporate vs. State