Extraterritorial Taxation: Is It All Our Fault?
Adam N. Michel
In a recent Tax Notes International article, I describe the evolution of controlled foreign corporation rules and international taxpayer information exchange as examples of the United States being a first mover in weakening international tax norms.
You can access the article here, although it is paywalled for the next month.
I’ve written a lot recently on the problems with the Organisation for Economic Co‐operation and Development’s (OECD) Two Pillar proposal... Читать дальше...