United States
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line
A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the recent OECD public consultation documents on tax certainty for Amount A of pillar one and related issues, and review key areas that remain undecided. -
Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the Internal Revenue Service’s (IRS) advance pricing agreement (APA) statistics for 2021, and the state of the IRS APA programme.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US describe the Whirlpool case and its implications for Subpart F planning and controversy.
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