News & Analysis as of

Organization for Economic Co-operation and Development Pillar 2 Tax Rates

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

A&O Shearman

What does Pillar Two mean for structured finance?

A&O Shearman on

Born of the OECD’s base erosion and profit shifting (BEPS) project, the Pillar Two rules introduce a global minimum corporate tax rate of 15% on multinationals of a certain size. The reforms reflect the outcome of an...more

BCLP

Impact of Pillar Two on Tax Risk Apportionment for a Corporate Sale

BCLP on

How do you draft a tax covenant for a corporate sale when the Seller Group is within the scope of a Pillar Two charge? This is an issue that will become increasingly relevant as we approach the Pillar Two start date at the...more

Walkers

Jersey and Guernsey response to Pillar Two Framework on global tax rates

Walkers on

Guernsey and Jersey have today issued a joint statement with the Isle of Man on their intentions to implement the OECD global initiative to set a minimum effective tax rate for the world’s largest multinational enterprises,...more

McDermott Will & Emery

International Legal Highlights | June 2022

EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE - On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more

McDermott Will & Emery

An Overview of OECD Pillar 2

McDermott Will & Emery on

The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more

McDermott Will & Emery

OECD Pillar 2 Q&A

McDermott Will & Emery on

WHAT IS THE AIM OF PILLAR 2 RULES? The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...more

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