2026

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.

The Trump administration’s newly floated 0.125% “land port maintenance tax,” pitched as a fix to align shippers using land ports with those subject to the Harbor Maintenance Fee, looks less like infrastructure policy and more like contingency planning now that the US Supreme Court has struck down the administration’s tariff program under the International Emergency Economic Powers Act.

This article examines the I.R.S.’s use of real-world profit data to challenge how Meta values offshore intellectual property for tax purposes. The piece highlights a significant shift in transfer pricing enforcement, with implications for cross-border income allocation, valuation of intangibles, and the taxation of multinational enterprises’ foreign earnings.

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This article analyzes the administration’s response to the Supreme Court’s ruling striking down core elements of its tariff program. Despite the legal setback, the president signals an intent to maintain aggressive trade measures through alternative mechanisms. The piece evaluates the economic rationale behind the administration’s trade strategy, the legal constraints imposed by the Court’s decision, and the potential consequences for global supply chains and U.S. trading partners.

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The Supreme Court’s nixing of US President Donald Trump’s “reciprocal” tariffs is throwing fresh confusion over the raft of trade deals negotiated by global partners as the inescapable reality of ongoing levies remains a threat.

The European Union is poised to freeze the ratification process of its trade deal with the US and is seeking more details from President Donald Trump’s administration on its new tariff program.