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U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework

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Competent Authority Resolutions and the Creation of BEAT Liability

  • By David Farhat, Mayowa Olujohungbe, and Bryan McGrane

David Farhat, Mayowa Olujohungbe, and Bryan McGrane explain why tax authorities can and should expediently address base erosion and antiabuse tax liability that may arise from taxpayers’ use of the advance pricing and mutual agreement program.

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