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What does the future hold for US adoption of the OECD’s two-pillar proposals?

Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.

In discussing where things stand in the United States regarding the OECD’s two-pillar tax proposals we start with two initial observations. First we have assumed a basic familiarity with the substance of the OECD’s proposals because it would needlessly lengthen this discussion to summarise them in any real detail. We will however discuss current US tax law insofar as it addresses some of the same issues as the two-pillar proposals and their mutual interaction. Second for better or worse the OECD’s proposals (and to some extent the OECD itself) have become subject to partisan disagreement between President Joe Biden’s Administration and its Republican Congressional opponents. Therefore the fate of the OECD proposals in the US...

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