2026
Lawmakers Announce Bill to Stop Corporate Inversions
Senate Democrats introduced the Stop Corporate Inversions Act to restrict further transactions that move a company’s tax residence abroad through acquisitions of smaller foreign corporations. The proposal signals renewed appetite to tighten the inversion rules and reinforce §7874-style constraints as part of a broader anti-base-erosion agenda. If enacted, it could narrow viable outbound restructuring paths and increase the tax friction of cross-border M&A involving U.S.-parented groups.
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Nathaniel Moran Announces Foreign Tech Deterrence Bill
Rep. Moran’s proposal would deny major federal business tax incentives to companies that use technology controlled by foreign entities of concern, tying tax eligibility to national security and data-risk considerations. The bill would effectively convert credits and incentives into a compliance lever for supply chain and technology governance, potentially affecting planning in manufacturing and tech-heavy sectors. It reflects a broader trend of using tax policy to advance geopolitical and cybersecurity goals, adding another layer of constraints to incentive-driven investment decisions.
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An End to Double Taxation
This opinion piece by the former chairman of the House Ways & Means committee discusses the administration’s agreement advancing a new global minimum tax framework aimed at reducing double taxation across jurisdictions. The article situates the proposal within broader OECD-led efforts to coordinate corporate tax rules and reallocate taxing rights internationally. It highlights ongoing political and policy debates surrounding implementation and sovereignty concerns. For international tax practitioners, the piece reflects the continuing evolution of multilateral tax coordination and the policy tensions surrounding global minimum tax enforcement.
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Tax Treaty Override Issue Has Nations Squaring Off in UN Talks
Countries with large tax treaty networks said that a prospective United Nations tax agreement on cross-border services would see far less uptake if it required an automatic override of existing treaties.
EU Tax Commissioner Is Not Ready to Cross the DST Bridge Alone
Commissioner Wopke Hoekstra said pillar 2 has “deteriorated” and pillar 1 remains stalled, but he is not ready to push an EU-wide digital services tax and wants to exhaust options to preserve the two-pillar project. He argued that an EU DST would be politically and technically difficult because DST countries would push their existing models, while other member states would demand trade-offs. Hoekstra also defended the Commission’s 2026 withdrawal of several stalled tax proposals (including DEBRA, Unshell, and a transfer pricing directive) while keeping older DST and “significant digital presence” proposals available as leverage.
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OECD Helping Countries Adopt ‘Amount B’ Transfer Pricing Method
The OECD is working with a number of countries to implement a simplified transfer pricing method broadly agreed to in 2021—even as questions continue to swirl about which, if any, countries beyond the US and Singapore will actually adopt it. The organization has been helping developing nations, in particular, assess the impact that adopting the method, known as Amount B, would have on their tax bases, and is working with countries that have decided to implement it, OECD senior transfer pricing adviser Mayra Lucas said.
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