2026

President Donald Trump effectively upended a global minimum tax deal signed by nearly 140 countries on his first day back in office, declaring other countries shouldn’t decide how US multinationals will be taxed.

This article examines widespread corporate litigation seeking refunds of tariffs imposed under executive authority later curtailed by the Supreme Court. The piece highlights the fiscal exposure facing the federal government and explores how invalidated cross-border levies functioned as de facto revenue measures with significant implications for international trade taxation.

To read the full article, click here (subscription required).

To read more, click here. 

Top negotiators at the United Nations in coming weeks will begin threading the needle between countries’ competing views of a new global tax treaty’s scale of ambition as deadlines for the deal’s first drafts draw near.

The European Commission’s upcoming tax simplification package won’t reopen the bloc’s global minimum tax directive, according to a senior EU official.

Both the Organization for Economic Cooperation and Development, through the Inclusive Framework, and the United Nations, through negotiations for the Framework Convention on Tax Cooperation, are doing serious work in developing the most significant reforms to international taxation in a century.

Companies are clamoring to bring their valuable intellectual property back to the US, as expanded tax benefits and the new side-by-side global tax system make repatriating suddenly more attractive, tax professionals said. But there’s a problem.

In early February 2026, the OECD released an updated edition of its Manual on Effective Mutual Agreement Procedures, consolidating and refining prior guidance on the MAP process through the entire lifecycle of a proceeding under bilateral income tax treaties. This article examines seven key takeaways from the updated Manual, highlighting its implications for tax departments in the current controversy environment. The Manual aims to improve the effectiveness and timeliness of MAP proceedings, potentially allowing competent authorities to focus on more complex disputes.

A US exemption from parts of the revised OECD global minimum tax agreement creates fresh uncertainty for multinationals preparing to file 2026 earnings reports.

October 8, 2021, marked the beginning of the Pillar Two era, when 137 countries (known as the Inclusive Framework and led by the OECD) signed a political agreement to domestically legislate a 15% minimum tax on all profits of multinationals that annually have at least €750 million of gross revenue. On January 5, 2026, the IF (now up to around 150 countries) signed another political agreement (the side-by-side (Sbs) agreement) that should serve to dissolve US objections that had been holding up full international adoption of Pillar Two. This article focuses on how the Sbs agreement affects US multinationals with Canadian subsidiaries.