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Pillar Two: GloBE Return and CbyC Safe Harbours

Cross-border Tax Talks

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Is There a Central Rules Engine?

I don't think that jurisdictions are going to implement these rules. I envision that this is going to be a very dynamic area. There's going to be, you know, over the next five years, there's going to been a mismatch of what countries are adopting and how they're doing it. This adds on more complexity than we've ever seen for USNCs obviously where we're not going to have the two pillars implemented at least in the next couple of years with Congress divided. But as jurisdictions or other countries implementing them will be Patchwork," he said.

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