North America
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line
A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the IRS’s APA statistics for 2022, and the state of the IRS APA programme. -
Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss enforcement-related proposals in US Treasury’s latest Green Book, and how they would change the tax compliance and enforcement landscape for large businesses.
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Sponsored by Galicia AbogadosSebastián Ayza and Federico Scheffler of Galicia Abogados explain the conditions under which a US fiscally transparent vehicle with Mexican-sourced income is entitled to Mexican tax relief.
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North American Jurisdictions