Squire Patton Boggs’ Jeff VanderWolk, addresses how the editor’s November 7 issue, provided plenty of food for thought regarding pillar 2, particularly the UTPR. Heydon Wardell-Burrus raised lots of questions. Allison Christians and Tarcísio Diniz Magalhães argued that the UTPR rests on a “use it or lose it” principle of international taxation.
Sol Picciotto said some interesting things, and Robert Goulder helpfully walked through the debate and concluded with the sensible idea of a multilateral instrument for pillar 2. Plus, Mindy Herzfeld suggested a new approach for addressing a crucial pillar 2 issue — namely, whether the United States has implemented a qualifying income inclusion rule.
*This article was first published in Tax Notes on November 14, 2022.