Bloomberg Tax
July 6, 2023, 4:34 PM

US Bill Attacking Foreign DSTs and UTPR Would Hit Canadians

Nathan Boidman
Nathan Boidman
Davies Ward Phillips & Vineberg LLP
Peter A.  Glicklich
Peter A. Glicklich
Davies Ward Phillips & Vineberg LLP

This commentary describes a recent development — proposed legislation introduced on May 25th in the GOP-controlled House of Representatives (H.R. 3665” or the “Bill”) — that if adopted could impose retaliatory taxes (and possible future trade and other sanctions) on citizens and companies from countries that adopt the OECD-sponsored “Pillars.” The Bill is called the “Defending American Jobs and Investment Act” and would add §899 to the Code and be entitled “Enforcement of Remedies Against Extraterritorial and Discriminatory Taxes.” As described further below, the main focus of the proposed legislation is on Pillar Two involving ...

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