Pillar 1, Amount A: Will The Zombie Arise?

Squire Patton Boggs' Jeff VanderWolk, addresses how the United States is clearly not ready (and may never be ready) to implement an agreement on pillar l's amount A regime, which would reallocate for tax purposes a portion of the profits of 100 or so of the world's largest and most profitable multinational enterprises.

Most of the reallocated profits would come from U.S. MNEs. The idea of reallocating profits of U.S. MNEs to other countries, thereby shrinking the U.S. corporate income tax base, does not appeal to legislators in Congress despite the key role played by the Biden administration in pushing the two-pillar deal in the G-7 and G-20 in 2021.

*This article was first published in Tax Notes on May 29, 2023.