10th Annual ITPF | Georgetown Law Conference

President Trump issued an order declaring that "any commitments made by the prior administration on behalf of the United States with respect to the Global Tax Deal have no force or effect within the United States," absent Congressional action. The order directs the U.S. Department of the Treasury to investigate whether countries are out of compliances with U.S. tax treaties or have implemented tax rules that are extraterritorial or disproportionately affect U.S. companies.

Under threat of retaliatory taxation from Congress, the Treasury Department negotiated a "side-by-side" agreement exempting U.S. companies from two of the three operative global minimum tax rules under Pillar Two to achieve its stated goal of protecting U.S. tax sovereignty. Critics viewed this as undermining a historic achievement in international tax cooperation among 140 countries.

This half-day conference will consider the concept of national "tax sovereignty," its operation in a globalized economy, and the scope of multilateralism in tax policy.

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