Allan Lanthier, a former advisor to the Canadian government, argues that when EU finance ministers next meet on April 5, they should abandon Pillar Two, which, he says, is a deeply flawed initiative that includes major changes on which countries had never previously agreed, including a new Domestic Minimum Top-Up tax and a significant rewrite of the Undertaxed Payment Rule.
Allan Lanthier, a former advisor to the Canadian government, warns it’s time to hit the emergency brake on the OECD’s model rules for Pillar Two; while close to 140 countries agreed to the October 2021 framework, they didn’t agree to these new model rules, which introduce a lot of uncertainty and complexity.
New York City Economist Dr. J. Harold McClure analyzes the Supreme Court of Canada’s November 26 decision upholding a taxpayer-favorable ruling in The Queen v. Alta Energy Luxembourg S.A.R.L., in which the legal issue revolved around charges of treaty shopping, but the appropriate valuation of . . .
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