U.S. Tax Review: Corporate Transparency, 3M Amicus Briefs, and Comments on Pillar 2 FTCs, Dual Consolidated Losses, and Amount B

By: Larissa B. Neumann , Julia Ushakova-Stein , Michael Knobler

In this installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein and Mike Knobler discuss an important Tax Court opinion on economic substance, the latest news on a challenge to IRS procedures for imposing international information return penalties, the Biden Administration’s proposal to raise the corporate alternative minimum tax rate, a federal trial court’s ruling that the Corporate Transparency Act is unconstitutional, and an alternative approach that jurisdictions can use in implementing Amount B of Pillar 1 of the new global tax regime.

Read the full commentary and analysis in Tax Notes.