2026
Republicans breathe sigh of relief as Supreme Court axes Trump tariffs
The Supreme Court’s ruling that struck down the sweeping global tariffs at the heart of President Trump’s economic policies has produced enormous cracks in the GOP’s outward show of party unity.
O’Leary says Supreme Court ’caused a nightmare’ with tariff decision
Millionaire investor Kevin O’Leary warned of a “major compliance cost” for business owners in the wake of the Supreme Court’s ruling that blocks President Trump from using emergency powers to impose sweeping tariffs.
Tariff Ruling Sets Off Scramble to Figure Out What Comes Next
Following the Supreme Court’s decision striking down President Trump’s use of emergency powers to impose global tariffs, companies are scrambling to determine whether they can recover billions in paid duties and how to respond to the administration’s newly announced 10% global tariff under a different legal authority. The article examines the legal uncertainty surrounding tariff authority and the practical consequences for multinational businesses and trade flows.
To read the full article, click here (subscription required).
Tariff Refunds Would Present Tax, Transfer Pricing Issues (1)
The Supreme Court’s decision to nullify a large swath of the Trump administration’s tariffs cleared the way for companies to seek refunds of tariffs already paid, which could come with a slew of transfer pricing issues for them to navigate.
Trump Signs 10% Global Tariff in Bid to Salvage Trade Agenda (2)
President Donald Trump imposed a 10% global tariff on foreign goods, moving quickly to preserve his trade agenda after the US Supreme Court struck down many of the levies he imposed last year.
Perfection as the Enemy of the Good — Redux: Pillar 2 After Side-by-Side
Lebovitz defends the OECD inclusive framework’s side-by-side pillar 2 package as a pragmatic compromise that accommodates U.S. international tax rules while preserving global minimum tax objectives. He argues that recognition of the U.S. GILTI/NCTI regime and related anti-base-erosion measures reduces conflict and encourages broader adoption of qualified domestic minimum top-up taxes. The piece frames the package as stabilizing the BEPS architecture, addressing developing country concerns, and setting the stage for the 2029 review.
To read more, click here.
U.S. Treasury Officials Declare Death of OECD Pillar 1
U.S. Treasury officials declared OECD pillar 1 effectively defunct, reopening debate over digital economy taxation and market-based allocation of taxing rights. While pillar 2 continues through the side-by-side agreement, Treasury signaled that amount A lacked domestic political viability and must be reconsidered in its entirety. The announcement marks a major inflection point in global tax reform and injects renewed uncertainty into multilateral negotiations over cross-border profit allocation.
To read more, click here.
Where’s the Business Participation in the U.N. Tax Convention?
This viewpoint critiques the limited participation of business stakeholders in negotiations over the U.N. Framework Convention on International Tax Cooperation and its early protocols. It highlights debates over new nexus standards, gross-basis withholding taxes, significant economic presence concepts, and alternatives to OECD amount B, emphasizing concerns about certainty and administrability. The article raises broader governance questions about transparency, neutrality, and structured engagement in the evolving U.N. tax architecture.
To read more, click here.
Tiger by the Tail: Indian Supreme Court Takes On Treaties
The Indian Supreme Court held that a Mauritius tax residency certificate is necessary but not sufficient for treaty benefits, permitting scrutiny of effective management and substance under GAAR principles. The decision suggests treaty relief may be denied when gains are not taxed in the residence jurisdiction, effectively introducing a subject-to-tax dimension into the India–Mauritius treaty. The ruling signals a more anti-avoidance-driven approach to treaty interpretation that could significantly affect inbound investment structures into India.
To read more, click here.
Member Companies
