My Publications
Transfer Pricing in Brazil: Towards Convergence with the OECD Standard
Transfer Pricing in Brazil: Towards Convergence with the OECD Standard
Spain’s Additional Wealth Tax on Taxpayers With $2.9 Million in Assets.
Spain’s Additional Wealth Tax on Taxpayers With $2.9 Million in Assets
Will the U.S. Fully Implement OECD Tax?
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 Journal Thomson Reuters
Estate Planning for Global Families
Estate Planning Journal, Thomson Reuters
March 2021
International Tax Journal
International Tax Journal / Thomson Reuters, August 2019
Article: International Tax Arbitration: Global Tax Competition: Corporate vs. State
International Tax Journal
International Tax Journal / Thomson Reuters, March 2019 Article: International Tax Arbitration: Challenges and Opportunities
Estudos de Tributação Internacional
Estudos de Tributação Internacional, 2019 (International Taxation Studies) Co-author Editor: Lumen Juris ISBN: 978-85-519-1577-6