Nothing new here. Alternative Minimum Tax was just one of many tax laws that overrode prior tax treaties. Last in time governs. https://t.co/skvL4Rp8zC
— Andrew Grossman (@andygr) October 4, 2021
(The above tweet was a response to a recent article in the Financial Post.)
This post is a comment on yesterday’s Tax Connections post “Ranking Members Warn Against Bypassing Treaty Process“. As is well known the United States has been hugely supportive of the International Tax Reforms known as “Pillar 1” (granting source country taxing rights to certain profits earned by certain multinationals) and “Pillar 2” (establishing a global minimum tax on the profits of certain multinationals). Apparently 136 of 140 countries have agreed to the two Pillars of international tax reform. The agreement signified a country’s commitment to make the necessary domestic changes to meet its international obligations.