The IRS released final and proposed regulations providing further guidance and addressing certain open issues under the base erosion and anti-abuse tax (BEAT). The final regulations, based partly on the IRS’s response to comments received, clarify previously proposed regulations, such as providing that certain amounts transferred in connection with a nonrecognition transaction are not base erosion payments. The newly proposed regulations would create a mechanism to reduce or eliminate application of the BEAT rules […]

Given the disruption in world order evidenced by recent elections, civil wars, mass protests and Brexit, perhaps it is not surprising that this is a time of great change in international taxation as well.

Countries have become alarmed that the nature of Internet business seems to be eroding many countries’ tax bases. Digital giants such as Google and Facebook, almost all of which are U.S. companies, are paying little tax despite having users that number […]