Challenges in Simplifying Tax Rules and Global Accounting

The chapter explores the challenges of simplifying complex tax rules while maintaining rule integrity, focusing on explicit aggregation rules and divergences from global accounting carrying values. It discusses guidance on transactions within the globe rules, particularly addressing the implications at the transfer order level and the avoidance of double taxation. Additionally, it delves into the complexities of allocating cross-border current taxes for US multi-nationals, emphasizing a mechanical approach and addressing issues related to blended regimes in various jurisdictions.