Document Type
Article
Publication Date
3-2025
Abstract
On January 20 President Trump issued two executive orders on international tax. The first order rejected the OECD’s two-pillar project, stating: The OECD Global Tax Deal supported under the prior administration not only allows extraterritorial jurisdiction over American income but also limits our Nation’s ability to enact tax policies that serve the interests of American businesses and workers. Because of the Global Tax Deal and other discriminatory foreign tax practices, American companies may face retaliatory international tax regimes if the United States does not comply with foreign tax policy objectives. This memorandum recaptures our Nation’s sovereignty and economic competitiveness by clarifying that the Global Tax Deal has no force or effect in the United States.
Recommended Citation
Avi-Yonah, Reuven S. "Is the UTPR Extraterritorial or Discriminatory?" Tax Notes Federal 117 (2025).
Comments
Reprinted with the permission of Tax Analysts.