ATO hits US tech giants for ‘billions’, inflaming tensions with Trump

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Fresh from lobbing a petrol bomb at KPMG on Wednesday in the form of a lawsuit over her sacking, the firm’s ex-operations chief Eileen Hoggett has headed to Europe for some rest and relaxation.

Sadly, for the hundreds of KPMG staff and partners axed because of the audit misconduct scandal in which Hoggett was instrumental, rather less holidaying is on foot. They  were instead busily refreshing their banking apps …

ATO hits US tech giants for ‘billions’, inflaming tensions with Trump

John Kehoe Sep 8, 2026 

The Australian Taxation Office has unveiled a contentious new rule to tax United States digital giants, including Amazon, Google and Netflix, potentially billions of dollars extra on their cloud computing and streaming services, escalating a dispute with the Trump administration.

The ATO on Friday released a final ruling on taxing software revenue earned in Australia and transferred offshore to overseas headquarters.

In April 2024 the US Treasury wrote to the Australian Treasury expressing alarm at an ATO draft tax ruling impacting multinational digital companies. Fairfax Media

The major change means income earned from cloud services operated by Amazon, Google and Microsoft, and music and video streaming services sold by Apple Music, Spotify and Netflix, will become taxable in Australia for the first time beyond the GST already levied on consumers.

In a world-leading move that breaks with other countries, the ATO has ruled that these service fees have a copyright or intellectual property element and are therefore taxable as a royalty payment when the money flows offshore to foreign parent companies.

Melbourne-based tax partner at US multinational law firm Jones Day, Niv Tadmore, said the ruling would have big implications for multinational companies and governments.

“Other countries may not share the ATO’s view, creating two critical risks for multinationals: maintaining global consistency of their tax positions and the real prospect of double taxation where another authority disagrees,” he said.

“Notably, the US Treasury has publicly raised concerns about earlier drafts of the ruling.”

The US Treasury has been fighting the move, writing at least twice to the Australian Treasury over the past five years about its concerns about the ATO’s previously well-telegraphed shift.

“The ATO’s position will almost certainly be tested in the courts, but litigation takes time.”

— Niv Tadmore, tax partner, Jones Day

The US disagrees that the payments are taxable royalties and therefore the Internal Revenue Service may not offer a credit to the American companies for paying the tax in Australia, tax experts said.

KThe move adds to tax tensions between Australia and the US, after US technology giants resisted the Albanese government’s News Bargaining Incentive, a 2.5 per cent tax on the Australian digital advertising revenue of technology giants such as Google, Meta, TikTok that do not strike content deals with local media outlets.

Big tech will also be impacted by plans by the Albanese government to toughen rules and penalties surrounding its social media ban for under-16s, which should pass parliament this week, following an eight-week delay.

Communications Minister Anika Wells will unveil draft digital duty of care legislation this week expected to enable a social media user to opt in to algorithms and be targeted by advertisers and other influence peddlers, rather than be automatically exposed as is currently the case.

Successive Labor and Coalition governments have toughened multinational tax laws in an attempt to force the US tech giants to pay more tax, but have had limited success in raising extra revenue from globally mobile digital services.

US-based giants Meta, Amazon, Netflix, Disney and Google made a combined $15 billion in revenue in Australia in 2024, but after shifting billions offshore for “distribution fees” or by reselling advertising for a parent company, they paid tax on significantly lower profits. Across the five companies, they paid a combined $254 million in company tax.

Google and Meta transferred almost $11 billion to offshore entities in service fees and reseller payments in 2025, with accounts showing the two technology giants paying just over $140 million in tax.

In April 2024, the US Treasury wrote to the Australian Treasury, expressing alarm at an ATO draft tax ruling impacting multinational digital companies and raising concerns it could breach the bilateral tax treaty between the two countries.

“The United States does not agree with the analysis and conclusions,” the US Treasury said in the April 5, 2024, letter.

“The interpretation that the payments are royalties would be contrary to long-standing internationally accepted treaty interpretation including...the OECD Model Tax Convention.”

An ATO spokesperson on Monday said following public consultation, the ruling provides greater certainty about how the ATO considers the royalty withholding tax rules apply to software arrangements.

In its industry-wide ruling that puts companies on notice, the ATO on Friday said software intermediation arrangements are royalties for the purposes of Australian royalty withholding tax.

“The ruling takes into account feedback received during consultation,” the ATO said.

“Broadly, the ruling explains that payments are royalties where they’re made for the use of, or the right to use, copyright or similar rights.

“This includes where a software intermediary (sometimes called a distributor) communicates, reproduces, modifies, or adapts the software, or otherwise exercises rights that are exclusive to the copyright owner.”

Under the ATO ruling, up to half of the royalty payment is taxable in Australia, at 5 per cent on gross payments to US parent companies, 10 per cent for payments to companies in the financial hub of Singapore and 30 per cent in countries Australia does not have an international tax treaty with.

The tax would be on gross revenue and deny deductions for costs.

A corporate tax adviser, speaking on the condition of anonymity, said it was difficult to quantify the amount of revenue at stake, but it could add up to “billions of dollars”.

Corporate Tax Association executive director Michelle de Niese said the ATO had not backed down on its earlier draft ruling and the taxation of intangibles was becoming the new global battleground in multinational tax.

“After a bright spot of global co-operation, I think we’re tipping into a period of tax fragmentation on intangibles and AI,” she said.

“These types of cases by revenue authorities, whilst understandable, are indicative of that.”

Tadmore said legal disputes in court were likely in the years ahead.

“The ATO’s position will almost certainly be tested in the courts, but litigation takes time. In the interim, expect a busy and intensive enforcement landscape.”

Amazon, Apple, Microsoft, Netflix and Spotify declined to comment or didn’t respond before deadline.

with Zoe Samios

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'Diminishing integrity of the public service': Podger's scathing take on secretary pay

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 'Diminishing integrity of the public service': Podger's scathing take on secretary pay

Departmental secretaries should get a pay cut in exchange for job security to safeguard the provision of frank and fearless advice, according to former top bureaucrat Andrew Podger.

"My strong suspicion is that most current secretaries would prefer such an arrangement," the former Australian Public Service commissioner said, suggesting a 20 per cent reduction in compensation and loss of office arrangements. 

Professor Andrew Podger argues that secretary pay is too high. Picture by Sitthixay Ditthavong

In a submission to the Remuneration Tribunal's review of APS bosses' circa-million-dollar pay packets, Professor Podger said wide public confidence in the remuneration of senior public servants "needs to be regained".

"The system must also achieve its fundamental purpose of attracting and retaining the skills and calibre needed," he wrote, saying the review was an opportunity to "give closer consideration to public service motivation" outside of financial factors.

The Remuneration Tribunal, which sets pay for secretaries and other top bureaucrats, is looking at "whether the current arrangements remain appropriate, effective and fit for purpose".

The current system, under which secretaries are appointed for five-year terms at the prime minister's discretion, was "diminishing integrity at the top of the public service," Professor Podger told The Canberra Times.

He said tenure was a contributor to "failures at the top of the public service" exposed by the Robodebt royal commission and Virginia Bell's inquiry into former prime minister Scott Morrison's appointment to multiple ministries.

With many secretaries - most of whom are paid more than $900,000 a year - recruited from within the public service, he said private sector salaries like those of top executives in ASX top 100-ranked companies were not the appropriate comparator.

Professor Podger said his experience served as an example of how many senior public servants moved through the APS.

"I moved from the small Housing and Regional Development Department to the huge Health and Family Services Department in 1996, continuing in the slightly smaller Department of Health and Aged Care in 1998," he said.

Secretary jobs 'not subject to competition': Rex Patrick

Former independent South Australian senator Rex Patrick said in a submission to the tribunal that secretaries' salaries needed a "reset" and should be benchmarked to "comparable positions in state bureaucracies [or] overseas".

"Secretaries' roles cannot be compared with the CEO of a company, as some like to suggest," Mr Patrick wrote.

"When the man running the country, the Prime Minister, gets a salary of $622,000 and departmental secretaries get much more, something is wrong.

"The tribunal ought not pretend that government need to attract the right people to secretary roles. The reality is that secretaries' jobs are not subject to competition."

He pointed to the many examples of career public servants in top roles, from Prime Minister and Cabinet Secretary Steven Kennedy - "plucked from his role as Treasury Secretary" - to Home Affairs Secretary Stephanie Foster, Attorney-General's Kathryn Jones, Defence's Megan Quinn and DFAT's Jan Adams.

The US had "got it right" with salaries of about $403,000 to head up "much larger agencies with much bigger budgets," he wrote.

Professor Podger acknowledged that remuneration needed to be "sufficient to attract and retain the high calibre required."

"I suggest that most secretaries be classified at the same level of responsibility (and remuneration), based on their having portfolio responsibilities and serving Cabinet ministers. 

"This would also avoid the current complexity of special remuneration arrangements when a secretary is transferred from one portfolio to another with a lower classification."

This would also remove the need for the PM&C secretary and APS commissioner to assign pay points within two classification levels.

Professor Podger said a "clear and consistent framework for the remuneration of deputy secretaries and other senior executives", from whom most departmental secretaries are appointed, was also needed to ensure that remuneration arrangements were "appropriate, effective and fit for purpose" across the APS.

Labor and the Coalition have rejected a "blunt" cap on secretaries' remuneration, as proposed by Tasmanian senator Jacqui Lambie in a private senator's bill examined by a parliamentary committee.

The Faceless War: How Artificial Intelligence Rewrote the Map of Power

Small Wars Journal: “A small number of private technology firms now build the infrastructure on which both military power and the public’s perception of reality depend. 

Drawing on a 2025 wargaming experiment at the U.S. Army Command and General Staff College and on the documented information war of the June 2025 Israel-Iran conflict, this essay argues that simulated combat and cognitive warfare increasingly depend on the same technological ecosystem — shared firms, infrastructure, and supply chains — with direct implications for doctrine, training, and mid-sized powers such as Brazil. A Hegemony Written in Code – Power has historically followed infrastructure: control of sea lanes defined the nineteenth century, control of oil and industry defined the twentieth. 

In this century, the decisive axis has shifted to digital infrastructure and artificial intelligence (AI). This is not a future possibility; it is a present condition. Whoever controls information systems can shape more than data: that control increasingly influences perception, behavior, and how populations interpret events. Every advanced AI model depends on a physical layer of semiconductors, data centers, and satellite links, which makes that physical layer, rather than any single algorithm, the true strategic terrain. 

Washington has increasingly treated China’s technological rise as a hegemonic challenge rather than mere commercial competition, since military capability, industrial autonomy, and normative leadership now converge on control of computing, data, and networks. 

Between the United States and China — and between the private companies that supply both — lies the central contest of contemporary geopolitics: a competition over semiconductors, advanced computing, and autonomous systems in which the winner sets the terms for every nation that depends on that infrastructure…”

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“You cannot get through a single day without having an impact on the world around you. What you do makes a difference, and you have to decide what kind of difference you want to make.” ~ Jane Goodall

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Americans Lost an Estimated $148 Billion to Online Scams & Crimes in 2025

Up Nearly 26% From 2024, $1009 Per Household Average, Americans lost an estimated $148.2 billion to online scams & crimes in 2025, up 25.8% from 2024, a per household loss of $1,009, according to an updated report from the Consumer Federation of America (CFA). 

This “true” cost of scams is over seven times higher than what was reported to the FBI in 2025. Further, over half of all reported losses involve cryptocurrency, which surged 21.93% since 2024, with $11.4B in reported losses and an estimated true cost of $80.7 billion. AI-enabled fraud, measured for the first time this year, added another $6.3 billion. 

The $148 billion estimate builds on the FBI’s Internet Crime Complaint Center (IC3) data, which recorded just $20.8 billion in reported losses for 2025 — underscoring the scale of harm that goes unreported to authorities. Seniors (60+), in particular, remained the largest targeted demographic and saw an increase of over 60% in reported losses, averaging a staggering $38,500 per reported incident. 

The under-20 age group remains the smallest, but saw a 198% increase in reported losses from 2024. “This update shows that the troubling trend of rapidly increasing scam losses continues while tech companies are too often allowed to avoid accountability,” said Ben Winters, Director of AI and Privacy at the Consumer Federation of America. “The good news is that policymakers are beginning to respond, from new lawsuits and the SCAM Act in Congress, to growing momentum in state legislatures across the country. 

But this crisis demands additional bold action through legislation, enforcement, and public education at every level, including holding tech companies accountable for the role they play in enabling online scams.”

 “Seniors are the top target for online scams, and AI is making those scams more convincing and harder to spot. The billions of dollars Arizona families are losing to fraud should be paying for groceries, rent, and other necessities,” said Senator Mark Kelly (D-AZ). “That’s why I introduced the bipartisan Senior Chatbot Protection Act to require companies to clearly disclose when consumers are interacting with AI and strengthen protections for older Americans. People deserve to know whether they’re talking to a machine or a person, and CFA’s report makes clear that Congress needs to act now.” 

The newly measured category of AI-enabled fraud – which added $6.3 billion to the national online scam total – includes technology that enables the creation of convincing synthetic content, such as social media profiles and personalized conversations, often in mass quantities. 

This AI-enabled content is becoming increasingly difficult to detect and easier to make.Social media platforms, specifically Meta-owned Facebook and Instagram, are the platforms most commonly associated with online scams. Investigative reporting has illustrated how these companies profit heavily from the presence of scam content on their platforms..”

The One Quality Most ‘Super-Agers‘

 YOU DON'T "CONSUME" ART MOTHERF****R. YOU EXPERIENCE IT. YOU FEEL IT. YOU ENGAGE WITH IT. YOU WRESTLE WITH IT. YOU LIVE IT. ART ISN'T A LITTLE MORSEL YOU GOBBLE UP.

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The One Quality Most ‘Super-Agers’ Share After 25 years of research on this notable group, here’s what stands out

Ralph Rehbock, age 91 and a Holocaust survivor, has a lot on his calendar. On the first Friday of every month, he joins a group of older men at a synagogue outside of Chicago for a meeting of MEL: Men Enjoying Leisure. Every Friday afternoon, he performs classics from the 1930s and 40s with the Meltones, the club’s singing group. And he’s shared his story of escape from Nazi Germany with thousands of school children over the years, through his work with the Illinois Holocaust Museum & Education Center.

Leigh Steinman, 82, spends much of his time working on art projects with the children who live in his Chicago neighborhood and watching the Cubs play at Wrigley Field, which is just a block away. Mr. Steinman worked at the stadium as a security guard for 17 years before retiring at the beginning of the pandemic (his prior career was as an advertising copywriter). But he still walks over three or four times a week during the summer to see former co-workers and fellow fans.

Mr. Rehbock and Mr. Steinman are both considered “super-agers,” people 80 and up who have the same memory ability as someone 20 to 30 years younger. Scientists at Northwestern University have been studying this remarkable group since 2000, in the hopes of discovering how they’ve avoided typical age-related cognitive decline, as well as more serious memory disorders like Alzheimer’s disease. A new review paperpublished Thursday summarizes a quarter century of their findings.

Super-agers are a diverse bunch; they don’t share a magic diet, exercise regimen or medication. But the one thing that does unite them is “how they view the importance of social relationships,” said Sandra Weintraub, a professor of psychiatry and behavioral sciences at the Northwestern Feinberg School of Medicine, who has been involved in the research since the start. “And personality wise, they tend to be on the extroverted side.”

This doesn’t surprise Ben Rein, a neuroscientist and the author of the forthcoming book, “Why Brains Need Friends: The Neuroscience of Social Connection.”

“People who socialize more are more resistant to cognitive decline as they get older,” Dr. Rein said. And, he added, they “have generally larger brains.”

Researchers think that may be because socializing could help to protect against declines in brain volume that happen with age and isolation. Loneliness, which is particularly common in older adults, can increase levels of the stress hormone cortisol, and if cortisol is elevated for long periods of time it can lead to chronic inflammation. That, in turn, could damage brain cells and even increase the risk for dementia.

By being more social in old age, super-agers may avert some of the atrophy. An analysis included in the new paper backs this up: The brain volume of super-agers tends to be more on par with 50- and 60-year-olds than with their octogenarian and nonagenarian peers.

Image

Much of super-ager Leigh Steinman’s socializing takes place at Wrigley Field, where he watches the Chicago Cubs and catches up with old friends.Credit...Lyndon French for The New York Times

Another notable difference is that super-ager brains tend to have more of a special type of cell, called von Economo neurons, that is thought to be important for social behaviors and is only found in highly social mammals — namely apes, elephants, whales and humans.

All those von Economo neurons “probably help them build and maintain powerful, strong social connections and social networks,” said Dr. Bill Seeley, a professor of neurology and pathology at the University of California, San Francisco. And that may have “a far-reaching effect on their overall well-being and health.”

But, Dr. Seeley added, this is likely just one of “a whole suite of neurobiological advantages that puts them in such good shape at this stage in life.”

For example, almost all 80-year-olds have signs of Alzheimer’s disease in their brains (whether or not they have the condition), but some super-agers have little to none. In addition, in super-ager brains, the functioning of a neurochemical that is important for attention and memory is better preserved.

Dr. Sofiya Milman, a professor of medicine and genetics at the Albert Einstein College of Medicine in New York, studies healthy centenarians. She said that they also tend to be extroverted and “have a positive outlook on life.”

There is a “chicken and the egg” conundrum, though. A person with better cognitive functioning may be more eager to go out and socialize, compared with someone who feels like their memory is declining. “Whether it’s the socialization that leads to maintenance of better cognition, or whether it’s the better cognition that leads to more socialization, I think it’s still open to debate,” Dr. Milman said.

Unfortunately, forcing yourself to be more social probably won’t be enough to turn you into a super-ager. Dr. Weintraub said super-agers’ preternatural ability likely comes down to their genetics and biology, as well as their behaviors.

But to Mr. Steinman, the importance of seeing his neighbors and friends at the ballpark is clear. “I think the sociability of Wrigley Field and where I live, my block, that’s what’s kept me going all this time,” he said.

Dana G. Smith is a Times reporter covering personal health, particularly aging and brain health.

A version of this article appears in print on Aug. 9, 2025, Section A, Page 18 of the New York edition with the headline: For ‘Super-Agers,’ Sharp-Witted and Over 80, Sociability Is a Trait They Share. Order Reprints | Today’s Paper | Subscribe

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