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The (helpful?) world of elections under the OECD´s Pillar 2 initiative by Zach Pouga Tinhaga

By: Tinhaga Pouga, Zach.
Material type: ArticleArticlePublisher: 2024Subject(s): SEGUNDO PILAR (OCDE) | TIPO MÍNIMO GLOBAL | CONTRIBUYENTES In: Tax Notes International v. 114, n.4, April 22 2024, p. 529-541Summary: Zach Pouga Tinhaga is a New York City-based principal in the international tax and transaction services group in the National Tax department of Ernst & Young LLP and an adjunct tax law professor at NYU. He thanks Candice James, Benjamin Satterthwaite, and Shivani Mehra for their contributions to this article. He also thanks JD Hamilton, Colleen O’Neill, Craig Hillier, and Barbara Angus for their helpful comments. In this article, Pouga Tinhaga examines pillar 2 elections for corporate taxpayers, summarizing the mechanics behind each election and its effects, and provides a preliminary generalized assessment of each election from the taxpayer’s perspective. The views reflected in this article are those of the author and do not necessarily reflect the views of Ernst & Young LLP or other members of the global EY organization. The information in this article is provided solely for the purpose of enhancing knowledge. It does not provide accounting, tax, or other professional advice.
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Zach Pouga Tinhaga is a New York City-based principal in the international tax and transaction services group in the National Tax department of Ernst & Young LLP and an adjunct tax law professor at NYU. He thanks Candice James, Benjamin Satterthwaite, and Shivani Mehra for their contributions to this article. He also thanks JD Hamilton, Colleen O’Neill, Craig Hillier, and Barbara Angus for their helpful comments. In this article, Pouga Tinhaga examines pillar 2 elections for corporate taxpayers, summarizing the mechanics behind each election and its effects, and provides a preliminary generalized assessment of each election from the taxpayer’s perspective. The views reflected in this article are those of the author and do not necessarily reflect the views of Ernst & Young LLP or other members of the global EY organization. The information in this article is provided solely for the purpose of enhancing knowledge. It does not provide accounting, tax, or other professional advice.

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