U.S. Tax Review: GLOBE and Nexus Rules, Final FTC Reg Comments, and Priority Guidance Plan Updates

Fenwick’s Larissa Neumann and Julia Ushakova-Stein co-authored the latest installment of their international tax commentary and analysis column for Tax Notes. The authors examine the latest developments in the Whirlpool, Mann Construction and Aptargroup cases; various OECD updates, including the global anti-base-erosion model rules, as well as the draft rules and the public consultation on nexus and revenue sourcing; comments on the final foreign tax credit regulations; IRS letter rulings on a qualified electing fund election, obligations in registered form and a cross-border restructuring; and updates to the 2021-2022 priority guidance plan.

The full article can be found on Tax Notes, and read more insights on fenwick.com.