2026

A US exemption from parts of the revised OECD global minimum tax agreement creates fresh uncertainty for multinationals preparing to file 2026 earnings reports.

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.

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.

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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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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The Supreme Court’s nixing of US President Donald Trump’s “reciprocal” tariffs is throwing fresh confusion over the raft of trade deals negotiated by global partners as the inescapable reality of ongoing levies remains a threat.

The European Union is poised to freeze the ratification process of its trade deal with the US and is seeking more details from President Donald Trump’s administration on its new tariff program.

This article reviews the legal and structural fallout following the Supreme Court’s invalidation of key Trump tariffs. It discusses the administration’s attempt to rely on alternative statutory authority and considers the broader institutional consequences for U.S. trade powers, global supply chains, and the stability of cross-border fiscal measures affecting international commerce.

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This article analyzes the Supreme Court’s decision limiting President Trump’s use of emergency tariff authority and examines the structural implications for executive power over cross-border fiscal measures. The ruling reshapes the allocation of economic authority between Congress and the president, with consequences for the future design of tariff-based revenue tools affecting international commerce.

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