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Make Europe Great Again

The day after the EU Parliamentary election in May 2019, I opened my newspaper in a café in Copenhagen and read the Berlingske Tidende’s morning

International Tax Update: OECD Releases Latest Edition of Model Tax Convention

On April 25, the Organisation for Economic Co-operation and Development (OECD) formally released the tenth edition of its Model Tax Convention on Income

Legislation Introduced Preventing Rolling Stock Acquisitions from Chinese Manufacturers

While the U.S. – China trade war continues, members of Congress have new concerns regarding China’s push to dominate the U.S. transit car market.

EU Efforts to Stem Abusive Tax Structures

It is of little surprise that the individual EU countries and European Commission for Competition have narrowed their focus on multinational companies

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Many have heard about the French data regulator CNIL imposing a $57 million (€50 million) fine on Google for violating the General Data Protection

Transfer Pricing: A Reporting Requirement for Multinational Corporations

It should come as no surprise that large companies often create affiliate and/or subsidiary companies to carry out various parts of their operations across

The End of an Era – LIBOR Interest Rate

The London interbank offered rate (LIBOR) is arguably one of the most important numbers in the finance world. You can find it within most variable-rate

Effective Dividends to Receive a 100% Deduction under New Proposed Treasury Regulations

It should come as no surprise that taxpayers seek to minimize tax liability and maximize tax benefit. One way to achieve that result is for taxpayers to

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An Inflow of Opportunity: Tax-Free Repatriation of Foreign Source Income from a Controlled Foreign Corporation

For more than fifty years, and subject to many exceptions, U.S. shareholders have been utilizing the controlled foreign corporation (“CFC”)

Increased Penalties for Failure to File an FBAR to Report Foreign Financial Assets

The Financial Crimes Enforcement Network (FinCEN) recently announced inflation-adjusted penalties for failure by U.S. persons to file a Report of Foreign

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