Ethan Saul Kroll

International Tax Topics After OBBBA: Six Months In, What Have We Learned?

Restructuring in a Shifting Global Tax Order

Thinking About Incorporating in the U.S.

Pillar 2 Update

US Tax Update

The Future of Tax Planning in a Pillar Two world

What the OBBBA International Tax Provisions Mean for Silicon Valley Companies

Pillar Two Update

Pillar Two Update

The OBBBA International Tax Provisions

Pillar 2

Novel Taxes, Planning Responses, and Outlook for US Retaliation

Nuances for Companies Re-domiciling Their Holding Structures to India from Overseas Markets

Still Crazy After All These Years: Anti-Hybrid Rules Remain Full Of Surprises

The Bumpy Road to Pillar Two Implementation: Politics, Pressure, and Practicalities

Cross-Border Combinations: Mergers, Amalgamations, and Other Monsters

The Superbowl of Tax: Legislative Activity in 2025

The OECD Pillars and Their Impact on U.S. Multinational Corporations and the U.S. Tax System

Pillar 2: Update on implementation, the corporate AMT, relevance of tax credits, and more

Pillar 2: Developments, Approaches, and Interactions with US tax regime

Pillar 2: Roundtable 4: Covered Taxes

OECD Pillar Two: Ready to Go?

A Method to the Madness: Managing U.S. Tax Liability Through Accounting Method Changes

Pillar Two: OECD’s Fourth Set of Administrative Guidance

Preparing for Challenges Based on the Economic Substance Doctrine (ESD), the General Anti-Avoidance Rule (GAAR) and Similar Rules

OECD Pillar Two (Global Minimum Tax): Almost One Year In - What Have We Learned?

OECD Pillar Two (Global Minimum Tax): Almost One Year In - What Have We Learned?

Tax Litigation Overview (Substance, Reg Invalidity, Etc.)

Is There a Future for Tax Planning?

Brace for Impact: What to Do to Get Ready for OECD Pillar Two (Global Minimum Tax) in 2024

Brace for Impact: What to Do to Get Ready for OECD Pillar Two (Global Minimum Tax) in 2024

Pillar Two

Brace for Impact: What to Do to Get Ready for OECD Pillar Two (Global Minimum Tax) in 2024

Pillar One and Pillar Two Developments, Trends, and Modeling

Putting the P(lanning) in P2

The FTC Regulations' Changing Shape: What Applies Today May Not Apply Tomorrow

Impact of Pillar 2 on Software / Digital Companies

Pillar Two

FTC Developments

Impact of the International Legislative Trends Toward 15% Minimum Tax

Impact of the International Legislative Trends Toward 15% Minimum Tax

OECD Pillars 1 and 2

Transfer Pricing Controversy and Defense Beyond Country-by-Country Reporting

Managing for Today and Planning for Tomorrow: The Final Foreign Tax Credit Regulations and the Future of International Tax Planning

Character and Valuation Issues Relating to Data

International structuring – selected topics including substance, holding companies and financing issues

International Tax Reform of Build Back Better

Biden Tax Plan Consequences for Software Structures

Now or Never: Planning Responses to Biden Tax Reform

Key Interactions of Recent TCJA International Regulations

Global Minimum Tax – The New International Tax Order and the Road Ahead for Singapore

International Tax - New Developments & Issues

FDII, BEAT, and GILTI – New Developments & Issues

Washington Update - Regs, Releases, Corrections, Possible Changes

International Tax Developments

ASC 740 - Tax Reform and New Developments

OECD - Digitalization of the Economy

Global Protectionism: What Tax Executives Need to Keep on the Radar Screen

Global Protectionism: What Tax Executives Need to Keep on the Radar Screen

Country Developments Focused on Software/Digital Companies

The Only Constant is Change: Tax Planning, Risk Mitigation, and Dispute Resolution in a Post-BEPS and US Tax Reform World

Sustainability and Defense of Principal and Holding Company Structures

Tax Treaties Case Updates

US Policy and Tax Reform (Outbound)

Structuring Intellectual Property Ownership

M&A in an Uncertain Environment

Repatriation Planning in an Uncertain Tax Climate

Industry Panel: Preparing for the End of Nowhere Income, Further Progress of BEPS/OECD including PE Attacks, Unilateral Actions, CbC, and Trump Tax Reform

Repatriation Planning in an Uncertain Tax Climate

The Future of International IP and Supply Chain Planning

Responding to the Expansion of Taxing Nexus

VAT Update

Indirect Tax

Disclosure and Protection of Company Information and Data

Disclosure and Protection of Company Information and Data

Disclosure and Protection of Company Information and Data

Addressing the Challenges of the Global Digital Economy: The Canadian Experience

Responding to the Evolving Permanent Establishment Rules and Unilateral Measures

Responding to the Evolving Permanent Establishment Rules and Unilateral Measures

Current Repatriation Strategies, with a Focus on the Outbound F

Indirect Tax

International Tax Update

Corporate Inversions

Planning Around the Dual Consolidated and Overall Foreign Loss Rules

Restructuring in an Uncertain Climate

Inversions

The September 2014 BEPS Developments and Future Predictions

The September 2014 BEPS Developments and Future Predictions

The September 2014 BEPS Developments and Future Predictions

The September 2014 BEPS Developments and Future Predictions

Planning responses to US tax reform, BEPS proposals and TPG Chapter VI concerning intangibles

OECD / BEPS Update

Characterization and server / PE developments

Incentives for the Present and Future

U.S. Income Tax and Treaty Aspects of Doing Business in the United States

The ins and outs of the section 956 export property exception in the context of consignment manufacturing

Tax 101: Introduction to post-acquisition restructuring

Introduction to Cross-Border Reorganizations