U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework
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A Tale of Two Subject-to-Tax Rules
Sol Picciotto, Jeffery M. Kadet, and Bob Michel analyze and compare the two proposals for a subject-to-tax rule to be included in tax treaties, one from the U.N. Tax Committee and the other from the G20/OECD inclusive framework on base erosion and profit shifting.
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