2026

Canada Should Follow in US’ Footsteps on Pillar Two Carve-Out

The OECD’s new “side-by-side” agreement for Pillar Two marks a decisive shift in the global minimum tax project—and not in Canada’s favor.

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UN Negotiator Casts Doubt on OECD Tax Deal’s Odds of Success

The OECD’s landmark global minimum tax deal isn’t guaranteed to succeed, according to the UN official leading negotiations on a new international tax convention.

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Japan Tweaks Global Minimum Tax Rules to Adopt Revised OECD Deal

The Japanese government approved changes to its global minimum tax system to implement the OECD’s recently revised agreement.

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A Second Bite at the Apple

Blanchard argues that the European Commission and EU institutions misunderstood a basic jurisdictional point in the Apple issue. The United States asserts residence-based taxing jurisdiction over 100% of a US taxpayer’s foreign income, with double tax relief through the foreign tax credit system rather than by allocating income among source countries.  Blanchard argues that the mismatch in frameworks led the Commission to treat income as “homeless” and to pressure an outcome that effectively forced a U.S. foreign tax credit for Irish tax on income that Ireland had no proper source claim to. She also pushes back on responses that focus on whether the Internal Revenue Service could have taxed the income earlier, framing timing as beside the point compared with the underlying jurisdictional premise.  

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UN Tax Committee Issues Options Paper on Cross-Border Taxation

United Nations negotiators working on new global tax rules issued a draft paper suggesting options for how and when countries can tax cross-border services that result from remote work and digitalization.

See attached the draft for the cross-border “protocol”.

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U.N. Issues Latest Draft of Tax Cooperation Framework Convention

The U.N. released an updated draft framework convention on international tax cooperation that would set principles for sustainable development, fair allocation of taxing rights, measures targeting high-net-worth individual avoidance/evasion, harmful tax practices, and expanded mutual administrative assistance and exchange of information, with protocols contemplated to implement specific rules.

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U.K. Confirms Huge Rise in Economic Crime Levy for Largest Firms

Pillar 2 as a New International Fiscal Law

Li argues that pillar 2 is more than a coordinated minimum tax and effectively functions as a new international fiscal law regime that constrains states’ fiscal policy choices, especially around tax incentives and effective rates. The IIR and the UTPR, as mechanisms that indirectly pressure source states to adopt qualified DMTTs or redesign incentives, meaning that what is really being “taxed” is other states’ forgone revenue. Pillar 2 operates as a common approach enforced through interlocking domestic laws and OECD guidance, creating a de facto supranational legal order without a formal treaty instrument. Side-by-side arrangements and expanding safe harbors may narrow pillar 2’s reach and reshape the durability of this networked sovereignty model.

HMRC Outlines Legislative Changes to Pillar 2 Top-Up Taxes

HMRC released a policy paper detailing legislative amendments to the U.K.’s Pillar Two Multinational Top-up Tax and Domestic Top-up Tax to align with OECD January 2025 administrative guidance and to fix issues relating to pre-regime deferred tax assets, cross-border allocation of deferred taxes, and a domestic top-up tax exclusion for REIT profits/losses.

Compliance Burden to Stay High Under Global Minimum Tax Deal

Simplification measures in the OECD’s new global minimum tax rules are unlikely to reduce the compliance burden for companies as they determine their tax liabilities under the new system, tax professionals said.

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