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" ... Is any of this really going to happen? Under Treasury Secretary Steven Mnuchin, you still have this idea of the whole thing being a safe harbor, or at least pillar 1 being a safe harbor. If you're an American, you don't have to worry too much about pillar 2 being a safe harbor because isn't that first rule, the income inclusion rule, a whole lot like GILTI under TCJA? It addresses the outbound opportunity for profit shifting. Isn't the undertaxed payment rule kind of like the BEAT that came in under TCJA? It addresses the inbound opportunity for profit stripping. ... "
" ... Of course, the argument is salient to more than just developing countries. A coalition of civil society organizations including Americans for Tax Fairness has suggested that the United States use the Biden administration’s proposed 28% corporate income tax rate for the pillar 2 income inclusion rule (IIR) and undertaxed payments rule. ... "
" ... Over the past decade Kenya has emerged as a digital leader within Africa, particularly in the realm of digital financial inclusion, like mobile money. But already officials feel that both domestic and international companies in the sector are undertaxed. ... "
" ... WalletHub then listed the states where the top 1 percent are most undertaxed – largely those heavily dependent on consumption taxes. Not coincidentally, WalletHub found the states where the bottom 20 percent were most overtaxed to be those heavily dependent on sales taxes. ... "
" ... “The aviation sector is severely undertaxed, only a handful of countries have ticket taxes and airlines don't pay a single cent of tax on their fuel, which according to the European Commission amounts to a €27 billion subsidy.” ... "