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Posts published in “FP News”

Exchange of information: disputes multiply

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/October 14, 2019  Some four years ago in this blog, I wrote about problems that would start to emerge as exchange…

OECD Pillar One and Two explained

The OECD has now two proposals in process:  Pillar One addresses the digital economy and Pillar Two sets forth a global minimum tax system; global anti-base erosion (GloBE)…

OECD Consulting on Digital Tax

The OECD published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprises (MNEs), including digital companies, pay tax wherever they…

NEW book: Transfer Pricing and Value Creation

Recently published:Petruzzi/TavaresTransfer Pricing and Value Creation, Linde-Verlag Dear Colleagues, The Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), is…

IRS Cryptocurrency guidelines

In 2014, the IRS issued Notice 2014-21, 2014-16 I.R.B. 938 (PDF), explaining that virtual currency is treated as property for Federal income tax purposes and providing…