The Tax Brief

In this episode of The Tax Brief, we examine the Australian High Court's closely watched Pepsi v. ATO decision. Our Australian tax controversy team discusses royalty withholding tax, diverted profits tax, and the key lessons for multinational businesses operating in Australia.

The "One Big Beautiful Bill” Act (OBBBA) made several changes to various corporate income tax provisions. During this episode, we will discuss some of the interplay of those changes with other areas of tax law, as such interplay gives rise to surprising results and opportunities.

Is a website “cookie” the same as an actual one for purposes of being a physical presence for tax purposes? In this episode of DLA Piper’s Tax Brief podcast, we welcome David Pope from our state and local tax group. We’ll unpack the cutting edge of state and local tax litigation to how states are rethinking apportionment and pushing the boundaries of § 86-272 in a digital economy. You’ll hear what’s really at stake as states wrestle with “look-through” approaches for software and services, test theories that cookies or chat functions create taxable presence, and much more!

In this episode, we focus on the rapidly developing market for transferable IRA (Inflation Reduction Act) credits, which are designed to incentivize green energy investments. Drew Young and Marc Casale will discuss how these credits work, the current state of the market, and what the future may hold as regulations and market practices evolve. They will explain how companies can take advantage of these credits, the challenges these credits present, and the broader implications of these credits on sustainability and tax planning.

In this debut episode of The Tax Brief, DLA Piper’s Steve Dixon, Elyssa Kutner, and Maruti Narayan unpack how shifting U.S. tariffs are disrupting global trade - and how integrated customs and transfer pricing strategies can help companies stay ahead. Maruti discusses how businesses can adapt supply chains and tax planning to address these disruptions. Elyssa provides an overview of tariffs and customs and how changes to these rules impact a company’s financial performance and stability of its supply chain.

In this episode, we examine the proposed international tax reform in the context of the 2025 budget reconciliation. Steve Dixon and Evan Migdail provide an overview of what happened in the legislative process this year and key proposals that were under consideration, especially those that would have affected multinational corporations. The discussion covers issues about scoring and the legislative process.