Sanctions Ordered in Finkelstein/Azeff Insider Trading and Tipping Decision

On August 24, 2015, the Ontario Securities Commission (“OSC”) released its long awaited Reasons and Decision on Sanctions and Costs in the...

U.S. Treasury Attempts to Influence OECD’S BEPS Initiative via Proposed Changes to U.S. Model Treaty

The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative...

Treaty Shopping – OECD Releases Revised Discussion Draft on BEPS Action 6

On May 22, 2015 the OECD released a revised discussion draft on “BEPS Action 6: Prevent Treaty Abuse” as part of its Action Plan on Base Erosion...

OECD Releases Proposed Changes to Permanent Establishment Rules

The OECD recently proposed recommendations for expanding the definition of “permanent establishment” in tax treaties.

OECD Discussion Draft Considers Controlled Foreign Corporation Rules

On April 3, 2015, the OECD released a discussion draft on Strengthening Controlled Foreign Corporation (CFC) Rules that stresses the importance of...

OECD Releases Discussion Draft on Tax Challenges of the Digital Economy

On March 24, 2014, the OECD released a discussion draft identifying the major tax challenges raised by the rapidly developing digital economy and...

OECD Releases Discussion Drafts on Hybrid Mismatch Arrangements

On March 19, 2014, the OECD released two draft discussion papers aimed at neutralizing the effects of hybrid mismatch arrangements, as part of its...

OECD Proposes Revisions to Tax Treaties to Prevent “Treaty Abuse”

The OECD proposes revisions to tax treaties to prevent “treaty abuse." Learn more.