2026
Corporate America’s Growing Quest for Tariff Refunds
This article examines corporate litigation seeking refunds of tariffs imposed under executive authority later overturned by the Supreme Court. The reporting highlights the fiscal and legal consequences of invalidated cross-border levies, including potential revenue exposure for the federal government and broader implications for the treatment of trade-based revenue measures in international economic policy.
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EU Tax Omnibus Expected to Be Neutral for Companies
The European Commission launched a consultation on a proposed “tax omnibus” package aimed at simplifying key EU direct tax directives, including the parent-subsidiary, interest and royalties, merger, ATAD, and dispute resolution directives. Officials emphasized that the initiative is intended to reduce compliance burdens while remaining broadly revenue-neutral across member states. Potential reforms, such as aligning CFC rules with pillar 2 and revisiting interest limitation provisions, reflect an effort to streamline EU corporate tax architecture without redistributing taxing rights.
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The Awkward Implications of an Undertaxed Profits Rule
The article explores the potential awkward legal outcomes of adopting the UTPR as an income tax, which could allow countries to tax activities they do not control or have authorized. The article considers alternative approaches to implementing the UTPR, such as civil penalty regimes or taxing deductible payments, to avoid these inconsistencies. It also examines the practical application of UTPR under the OECD's GLOBE rules and discusses its implications for multinational enterprises, particularly in cases like India, Australia, and Kenya.
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The $130 Billion Race for Companies to Get Their Tariff Money Back
This article examines widespread corporate litigation seeking refunds of tariffs imposed under executive authority later curtailed by the Supreme Court. The piece highlights the fiscal exposure facing the federal government and explores how invalidated cross-border levies functioned as de facto revenue measures with significant implications for international trade taxation.
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U.S. Focusing on OECD Guidance for Pillar 2 Side-by-Side Package
The U.S. is prioritizing guidance related to the OECD's Pillar 2 side-by-side package to ensure efficient global implementation of the GLOBE rules. Treasury official Isaac Wood highlighted the need for clarity in resolving technical gaps, such as those concerning intragroup financing and the side-by-side safe harbor. The U.S. remains heavily engaged in the technical aspects of Pillar 2 to address issues impacting U.S.-headquartered multinational enterprises and ensure alignment with domestic tax laws.
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The Side-by-Side Agreement Reshapes US Canadian Subsidiaries’ Tax
October 8, 2021, marked the beginning of the Pillar Two era, when 137 countries (known as the Inclusive Framework and led by the OECD) signed a political agreement to domestically legislate a 15% minimum tax on all profits of multinationals that annually have at least €750 million of gross revenue. On January 5, 2026, the IF (now up to around 150 countries) signed another political agreement (the side-by-side (Sbs) agreement) that should serve to dissolve US objections that had been holding up full international adoption of Pillar Two. This article focuses on how the Sbs agreement affects US multinationals with Canadian subsidiaries.
Trump’s New Land Port Maintenance Tax Shouldn’t Be Tariff Plan B
The Trump administration’s newly floated 0.125% “land port maintenance tax,” pitched as a fix to align shippers using land ports with those subject to the Harbor Maintenance Fee, looks less like infrastructure policy and more like contingency planning now that the US Supreme Court has struck down the administration’s tariff program under the International Emergency Economic Powers Act.
I.R.S. Tactics Against Meta Open a New Front in the Corporate Tax Fight
This article examines the I.R.S.’s use of real-world profit data to challenge how Meta values offshore intellectual property for tax purposes. The piece highlights a significant shift in transfer pricing enforcement, with implications for cross-border income allocation, valuation of intangibles, and the taxation of multinational enterprises’ foreign earnings.
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Is the EU Tax List Creating a Competitiveness Problem?
Business representatives questioned whether the EU’s tax blacklist and the defensive measures it triggers undermine the bloc’s competitiveness, particularly following Vietnam’s addition to the list. The article examines how denial of deductions, withholding consequences, and treaty interactions create uneven compliance burdens across member states. It also explores the interaction between the blacklist regime and OECD Pillar 2, with companies increasingly using the global minimum tax framework to define low-tax jurisdictions.
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Trump’s Trade Gamble Will Continue, Despite Supreme Court Rebuke
This article analyzes the administration’s response to the Supreme Court’s ruling striking down core elements of its tariff program. Despite the legal setback, the president signals an intent to maintain aggressive trade measures through alternative mechanisms. The piece evaluates the economic rationale behind the administration’s trade strategy, the legal constraints imposed by the Court’s decision, and the potential consequences for global supply chains and U.S. trading partners.
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