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Gary D. Sprague

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Mr. Sprague was one of five business representatives selected by the OECD to participate in the OECD Technical Advisory Group ("TAG") on Tax Treaty Characterisation Issues Arising from E-Commerce, and was elected chair of the business representatives on the TAG. He also was appointed by the OECD to serve as the business co-chair on the Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits. He was the Co-General Reporter for the subject Taxation of Income Derived from Electronic Commerce for the International Fiscal Association 2001 Congress, and is a co-author of BNA Tax Management Portfolio No. 555, Federal Taxation of Software and E-Commerce. He is the General Reporter for the subject Big Data and Tax – domestic and international taxation of data driven business for the International Fiscal Association 2021 Congress. He also is a regular contributor to the Tax Management International Journal's Leading Practitioner Commentary.

Amount B was introduced as a “fixed return” on “baseline marketing and distribution activities” in the October 2020 Blueprint of Pillar One, and was seen as a critical component of the Pillar One deal
Following the long-awaited release of the consultation document on 8 December 2022 and subsequent public commentary received, the OECD/G20 Inclusive Framework on BEPS published a consultation document on Amount B on 17 July 2023, creating renewed momentum and putting Amount B back into the international tax spotlight.