On Tuesday, 20 December 2022, the OECD released a highly anticipated consultation document on Digital Services Taxes (DSTs) and relevant similar measures. This consultation document provides draft articles for inclusion in the Multilateral Convention to implement the agreement reached by members of the Inclusive Framework with respect to DSTs and relevant similar measures.

In brief The Tax Cuts and Jobs Act of 2017 (Public Law 115-97) (TCJA) made significant changes to Section 163(j) effective for tax years beginning after December 31, 2017. On December 28, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (“Proposed Regulations”) implementing the amendments to Section 163(j)…

The Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued the highly anticipated final regulations (the “Final Regulations”) implementing the base erosion and anti-avoidance tax (the “BEAT”) on December 2, 2019.  Treasury and the IRS simultaneously issued proposed regulations (the “Proposed Regulations” and with the Final Regulations, the “Regulations”).…