Blueprints for a new international tax regime fit for the digitalizing global economy were published by the OECD/G20 Inclusive Framework on BEPS (the Inclusive Framework) on October 12, 2020. Because the new regime represents “global law” and introduces concepts and rules not found in existing domestic and treaty laws, a parallel tax universe is […]
Monthly Archives: November 2020
Are Gig Workers Independent Contractors or Employees?
On November 3, 2020, Californians approved Proposition 22 exempting gig companies from legislation classifying their workers as employees. The ballot initiative was the most expensive in the State’s history with Uber and its allies spending over $200 million to achieve 58% of the vote. It undermines Assembly Bill 5, which presumes workers to be […]
Things Go Better with Coca-Cola? Well, Maybe Not Always
On Wednesday November 18, 2020, the United States Tax Court, via the pen of a very able Judge, issued the decision in a very important transfer pricing case, The Coca-Cola Company & Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent, 155 T.C. No. 10. Caution is always required in reading the tax decisions of […]
The Supreme Court's Accumulating Tax Brief - To What End?
A question that has lingered through the Summer and into the Fall has been answered in the last couple of days. Leave of the Supreme Court of Canada has been sought by the tax authorities to appeal the Federal Court of Appeal's early Summer decision in Cameco. If the Supreme Court grants leave, it […]