Ethan Kroll

Mar 12, 2024 | news.bloombergtax.com | Ethan Kroll |John BettAidan Barlow |Young-Eun Choi

It isn’t clear how §267A applies in a Pillar Two world, and Treasury and the IRS may want to think twice about incorporating Pillar Two into §267A, say Baker McKenzie practitioners. The Pillar Two rules combine the income and loss of all related entities that are located in the same jurisdiction for purposes of determining whether any Pillar Two top-up tax is owed for that jurisdiction.

Oct 26, 2023 | news.bloomberglaw.com | Ethan Kroll

Recent amendments to Singaporean tax law may increase the Singaporean tax liability of multinational groups that are engaging in routine asset sales and restructuring transactions, even when the transactions otherwise lack nexus with Singapore. Historically, Singapore did not tax capital gains.

May 12, 2023 | globalcompliancenews.com | Simone Bridges |Ethan Kroll

On 31 March 2023, the Australian government released draft legislation and an explanatory memorandum regarding a new anti-avoidance measure, which prevents large multinational enterprises from claiming tax deductions for payments relating to intangibles ‘‘connected with low corporate tax jurisdictions’’.