The Tax Impact of Replacing GILTI With a Pillar 2 IIR for 85 Large U.S. Corporations
The authors compare the estimated tax impact of global intangible low-taxed income and a pillar 2 income inclusion rule for 85 large U.S. nonfinancial corporations and find that aggregate taxes would have been higher under pillar 2.
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IRS, Canada Agree on World Cup Participants’ Income Allocation (06/10/2026)
Participants of the 2026 FIFA World Cup can use a proportional formula to allocate the prize money and other compensation they receive among the countries hosting the tournament, the IRS said Wednesday.
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Australia’s Tax Proposals Mean No Capital Gain Without Pain (06/10/2026)
Australia is proposing changes to its country’s capital gains framework by expanding what is considered "real property." The proposed law applies retroactively to 2006. Under the proposed laws, real property would be given a broad statutory definition. This broadens the Australian tax base for foreign investors.
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US May budget deficit shrinks but customs collections turn negative due to tariff refunds
This article reports that tariff refunds exceeded gross customs collections, causing net customs receipts to turn negative for the month. The development shows how tariff refund administration following litigation over emergency tariffs can affect customs revenue and monthly government receipts data.
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Brazil Expects OECD’s Side-by-Side Status Decision Within Months
Brazil expects the OECD to decide whether it will be included in the side-by-side package in August after submitting a request in February. Inclusion would exempt multinational groups headquartered in Brazil from the global application of pillar 2 rules. The U.S. is the only country included in the side-by-side package.
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OBBBA Restores R&E Expensing, Alters Multinational Tax Strategy
The OBBBA, delivers the long-anticipated return of immediate deductibility of domestic Research & Experimental, or R&E, expenditures. While the baseline cash flow benefits are clear—including options to accelerate deductions for costs capitalized between 2022 and 2024—the restoration of R&E expensing triggers significant ripple effects across a company’s broader tax profile. Altering how and when R&E costs are deducted creates a chain reaction across other complex tax frameworks. This article discusses these interconnected impacts and outlines practical considerations for leadership.
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Asian Countries Find $1.8 Billion From Tax Information Exchange
Asian countries participating in the OECD’s tax transparency program were able to recover at least €1.6 billion ($1.8 billion) in additional revenue in 2025, according to a report released by the organization Tuesday. The report documents the progress of the Asia Initiative, a project to increase tax transparency in the region, with 18 members including Vietnam, Brunei, Indonesia, Korea, India, China, Hong Kong, and Pakistan.
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