Published by Tax Notes
There is an increased likelihood of double taxation when operating activities under a corporate structure. In an effort to alleviate this, Congress has implemented various deductions that help reduce or eliminate double taxation on corporate earnings when distributed as dividends to other corporations. One such “dividends received deduction”, found in section 245 is intended to eliminate double taxation on US source earnings that have already been subject to US tax. However, the interaction of section 245 with another provision, section 956, may in fact result in unintended double taxation.
A&M Tax professionals Alon Kritzman, Kenneth Brewer, and Logan M. Kincheloe advance arguments for a favorable outcome and ask the Government to resolve the issue as a matter of certainty.
Read the full article
Overview of the BMF Instruction Sheet on Cross-Border Audit Cooperation
July 24, 2025
With its updated instruction sheet on cross-border audit cooperation, the German Ministry of Finance signals a stronger focus on coordinated tax enforcement. Joint and simultaneous audits are gaining relevance – especially in transfer pricing matters. For multinational groups, this means greater pressure to ensure consistency and audit readiness across jurisdictions.
PMK 37/2025: New Indonesia Regulation on Withholding of Article 22 Income Tax by E-Commerce Platforms
July 23, 2025
Learn how PMK 37, Indonesia's new e-commerce income tax regulation, expands the tax base and modernizes tax collection procedures under Article 22.
Announcement to Delay Tariffs to August 1, 2025: Implications for Pan-Asia Region
July 24, 2025
With US tariffs set to commence on August 1, 2025, discover the implications for affected Pan-Asia countries.
Alvarez & Marsal Tax Launches Indonesia Tax Practice Led by Jaap Zwaan
July 22, 2025
Alvarez & Marsal Tax, (A&M Tax), an affiliate of leading global professional services firm Alvarez & Marsal (A&M), today announced the launch of its Indonesia tax practice, further strengthening its presence in Asia.