Around the GloBE: Tracking the Pillar Two Rules' Progress

In this episode, we unpack the Supreme Court's recent decision holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to impose tariffs, discuss how importers might pursue refunds, and consider what that means for Trump's trade policy going forward.

In this episode of Inside International Tax, we examine recent U.S. and global tax developments that have leveled the playing field for U.S. and foreign multinationals, the non-tax factors that may driving the decision whether to inbound into the U.S., and the potential costs to inbounding.

In this episode, we explore the evolving landscape for sovereign wealth and foreign government pension funds under section 892, highlighting the latest regulatory developments, practical implications for asset managers, and how new guidance is shaping investment strategies and compliance for global investors in the U.S. market.

In this episode, we examine the impact on US and foreign multinationals of the OECD's Side-by-Side Package, which includes the long-awaited Side-by-Side Safe Harbor and other guidance and safe harbors intended to reduce the compliance costs of the GloBE system and protect substance-based credits.

In this episode of Inside International Tax, we examine how recent OB3 legislative changes - including changes to domestic R&E expenses, the reinstatement of 100 percent bonus depreciation, and modifications to section 163(j) and FDII - interact with BEAT and CAMT, and what these developments mean for taxpayers.