Apr 28, 2021

International Taxation of the Digital Economy: Can the OECD Unify Its Members?

As the global economy rapidly shifts and accelerates, the OECD has been focusing intently on developing and strengthening international tax rules in recent years.  Back in February 2013, the OECD released a report addressing its concerns that existing international tax standards do not reflect an increasingly global economy, and more specifically, an ever-growing digital economy.  The OECD is focused on answering two key questions that frequently come up: First, as multi-national enterprises (MNEs) make up a larger proportion of the global economy over time, and as more MNEs offer digital products and services to consumers worldwide, where is the value… Read more


May 24, 2012

Status Update: I’M OUTTA HERE!!! #EXPATRIATE

Authored by: Steven A. Richman Eduardo Savarin, one of Facebook’s co-founders, recently announced that he renounced his U.S. citizenship in September of 2011, several months in advance of Facebook’s initial public offering (“IPO”).  The resulting tax consequences (not to mention the political fallout from Washington) offer an interesting case study into the Internal Revenue Code’s expatriation rules, which are covered in Section 877A. Per Section 877A, individuals who are “covered expatriates” are treated as selling all of their assets for their fair market value (e.g., mark-to-market) upon their expatriation (thereby triggering income tax on any built-in-gain), even if they don’t… Read more