If you have been concerned about how the OECD’s “Pillar 2” proposal would apply to U.S. companies and their foreign affiliates, you are not alone. For years, since the OECD initiated its BEPS project in 2015, a key issue was how the international community would stop the ubiquitous efforts by multinational companies to allocate material profits to low or no tax jurisdictions, hence reducing their worldwide tax obligations.
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