For those interested in tax treaty implications of the latest US tax reform, we recently published an article with Tax Notes International that took a specific position on an issue being highly contested in the international tax community. While we did not request anyone to “challenge” our conclusion, we stated that we would love to be enlightened as to the treaty connections to the tax imposed under the BEAT. In any event, a current tax professor / former Treasury official took the “enlightenment” request as a “challenge”. You can read our original article; the “challenge”; and our response to the challenge by following the links above and below.
As international tax nerds, we appreciate the opportunity to debate the issues at hand and to bring the highest level of service to our clientele. We love to be challenged – it keeps the brain young!!