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130 countries join the OECD’s framework for international tax reform

By Robert E. Gaut & David M. Ward

July 5, 2021

Significant progress has been made in the efforts of the OECD to reach international consensus on the BEPS 2.0 proposals. Broadly, the proposals are aimed at addressing challenges relating to taxation of the modern digital economy. The 139 country OECD Inclusive Framework meeting concluded on 1 July 2021, with 130 countries and jurisdictions, representing in aggregate over 90% of global GDP, agreeing to the two pillar approach to international tax reform. Among those to agree…

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Treasury’s Green Book Provides Details on the Biden Administration’s Tax Plan

By David S. Miller, Muhyung (Aaron) Lee, Amanda H. Nussbaum & Talia Jaffe

June 15, 2021

On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” The Green Book summarizes the Administration’s tax proposals contained in the Budget. The Green Book is not a proposed legislation and each of the proposals will have to be introduced and passed by Congress. The Green Book proposes to: Increase in…

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Court of Appeal overturns High Court and holds that tax claim notice was valid

By Stephen Pevsner & Katerina Heal

May 11, 2021

This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer to the sellers under a sale and purchase agreement (“SPA”) of a potential claim under a tax covenant complied with the requirements of the SPA. As a reminder of the facts, the case…

Tax Talks

Tax Provisions of the American Families Plan

By David S. Miller, Muhyung (Aaron) Lee, Amanda H. Nussbaum, Stuart Rosow, Martin T. Hamilton, Tony Meyer, Jr. & Sean Webb

May 5, 2021

On Wednesday, April 28th, the White House announced the American Families Plan, the “human capital” infrastructure proposal. The American Families Plan would spend $1.8 trillion, including $800 billion in tax cuts over ten years, offset by $1.5 billion in new taxes over the same period. This blog summarizes the tax provisions of the American Families Plan. Tax Cuts The American Families Plan proposes extending the expanded Affordable Care Act premium tax credits and the…

Tax Talks

Comparison of the Biden Administration and Senate Finance Committee International Tax Proposals

By David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum, Stuart Rosow & Tony Meyer, Jr.

April 12, 2021

On March 31, 2021, the Biden administration released a factsheet for the “Made in America Tax Plan”. On April 5, 2021, Senate Finance Chair Ron Wyden (D-Ore.) and Senators Sherrod Brown (D-Ohio) and Mark Warner (D-Va.) released “Overhauling International Taxation: A framework to invest in the American people by ensuring multinational corporations pay their fair share” (the “Senate Finance Plan”), a parallel set of proposals to the Made in America Tax Plan. On…

Tax Talks

The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposals

By David S. Miller, Muhyung (Aaron) Lee, Martin T. Hamilton, Amanda H. Nussbaum & Tony Meyer, Jr.

April 5, 2021

On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America Tax Plan”, a tax proposal that would generate revenue to pay for the American Jobs Plan spending. The White House estimates that the Made in America Tax Plan will raise $2 trillion in tax revenue over the next 15 years. The…

Tax Talks

UK Budget 2021

By Catherine Sear & Richard Miller

March 4, 2021

The UK has now been in lockdown, on and off, for the best part of a year. With the COVID-19 vaccination programme now in full swing in the UK, and hopefully with light at the end of tunnel, attention has inevitably turned to the question of “how are we going to pay for it all?”. Sweeping and significant tax rises have been feared and, following last year’s Office of Tax Simplification (OTS) review into capital…

Tax Talks

COVID-19: OECD updates its guidance on residence and permanent establishments

By Stephen Pevsner & Philip Gilliland

February 5, 2021

Background From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD published guidance on the impact of COVID-19 on double tax treaties (DTTs), including in relation to tax residence, tie breakers and permanent establishments (reported by us in Tax Talks). When reporting on the previous guidance we…

Tax Talks

Regulations on Executive Compensation Excise Tax (Section 4960) for Tax-Exempt Employer and Their Affiliates Finalized

By Seth Safra, Amanda H. Nussbaum, James Huffman & Katrine Magas

February 2, 2021

Employers that are tax-exempt or have tax-exempt affiliates (for example, a foundation) should pay close attention to a 21% excise tax under Section 4960 of the Internal Revenue Code on certain executive compensation. Final Regulations under Section 4960 are described here. The discussion includes traps for the unwary. Please reach out to your Proskauer contact to discuss how these rules affect your organization.…

Tax Talks

Section 1061 Final Regulations on the Taxation of Carried Interest

By Jeremy Naylor, Amanda H. Nussbaum, Scott S. Jones, David S. Miller, Stephen Severo, Brianna Reed & Kaitlyn L. Flynn-Rozanski

January 14, 2021

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations [1] (the “Final Regulations”) providing guidance on Section 1061 of the Internal Revenue Code (the “Code”).[2] The Final Regulations modify the proposed regulations [3] (the “Proposed Regulations”) that were released in July of 2020. We previously discussed the Proposed Regulations with a series of “Key Takeaways” in our client alert published here…

Tax Talks

The Proskauer Tax Blog

Blog Authors

130 countries join the OECD’s framework for international tax reform

Treasury’s Green Book Provides Details on the Biden Administration’s Tax Plan

Court of Appeal overturns High Court and holds that tax claim notice was valid

Tax Provisions of the American Families Plan

Comparison of the Biden Administration and Senate Finance Committee International Tax Proposals

The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposals

UK Budget 2021

COVID-19: OECD updates its guidance on residence and permanent establishments

Regulations on Executive Compensation Excise Tax (Section 4960) for Tax-Exempt Employer and Their Affiliates Finalized

Section 1061 Final Regulations on the Taxation of Carried Interest

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