2026

U.N. Protocol Would Address Disputes Under Existing Tax Treaties

A draft protocol on dispute prevention and resolution under the U.N. tax cooperation framework would focus on resolving cross-border tax disputes between states arising under existing bilateral or multilateral tax treaties, while also exploring optional mechanisms for no-treaty situations, expanded MAP tools, coordinated APAs, and a possible U.N.-led transfer pricing task force. 

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‘Side by Side’ Global Tax Deal Tests Pillar Two’s Staying Power

The OECD’s long-awaited side-by-side package is a pragmatic attempt to preserve the global minimum tax architecture while accommodating the unique position of US multinationals. That pragmatism, however, comes with limits.

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EU Sees Reopened OECD Digital Tax Talks Departing From Old Plan

There is “still willingness from all jurisdictions” at the OECD to restart stalled negotiations for a global tax on digital services, but the talks will likely deviate from the framework’s current construction, according to a senior EU official.

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UN Panel Plans Task Force on Access to Transfer Pricing Info

United Nations negotiators working on a new global tax treaty plan to establish a task force to explore and identify practical options for improving countries’ access to transfer pricing information.

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Global Tax Deal Sparks Fear US Law Will Be Tougher to Change (1)

A global agreement to exempt US multinationals from key parts of the 15% global minimum tax is raising concerns that its rules may tie the hands of Congress to make corporate-friendly changes to the US tax code in the future.

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Canada Should Follow in US’ Footsteps on Pillar Two Carve-Out

The OECD’s new “side-by-side” agreement for Pillar Two marks a decisive shift in the global minimum tax project—and not in Canada’s favor.

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UN Negotiator Casts Doubt on OECD Tax Deal’s Odds of Success

The OECD’s landmark global minimum tax deal isn’t guaranteed to succeed, according to the UN official leading negotiations on a new international tax convention.

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Japan Tweaks Global Minimum Tax Rules to Adopt Revised OECD Deal

The Japanese government approved changes to its global minimum tax system to implement the OECD’s recently revised agreement.

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A Second Bite at the Apple

Blanchard argues that the European Commission and EU institutions misunderstood a basic jurisdictional point in the Apple issue. The United States asserts residence-based taxing jurisdiction over 100% of a US taxpayer’s foreign income, with double tax relief through the foreign tax credit system rather than by allocating income among source countries.  Blanchard argues that the mismatch in frameworks led the Commission to treat income as “homeless” and to pressure an outcome that effectively forced a U.S. foreign tax credit for Irish tax on income that Ireland had no proper source claim to. She also pushes back on responses that focus on whether the Internal Revenue Service could have taxed the income earlier, framing timing as beside the point compared with the underlying jurisdictional premise.  

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UN Tax Committee Issues Options Paper on Cross-Border Taxation

United Nations negotiators working on new global tax rules issued a draft paper suggesting options for how and when countries can tax cross-border services that result from remote work and digitalization.

See attached the draft for the cross-border “protocol”.

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