Category: Tax Law

  • OECD Pillar Two-Global Minimum Tax & US Tax Reform

    OECD Statement on Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy, issued on October 8, 2021, updates and finalizes a political statement by 136 OECD member countries of the Inclusive Framework (IF) to fundamentally reform international taxation. Pillar One attempts to ensure a fairer distribution of profits and taxing […]

  • Seeking Better Tax Treatment on Litigation Funding

    In the past decade, the nascent litigation funding entrepreneurs entered with an appealing nomenclature of offering to litigation parties and attorneys “non-recourse loan:” namely, the funding loan needs not be repaid if the underlying litigation produces no monetary recovery or proceeds. On the obligation to repay, a typical non-recourse provision reads: If the claimant does […]