Avi-Yonah, Reuven S. - 2023
In recent months, there has been a sharp increase in criticism leveled in the US against Pillar 2 of the G20/OECD BEPS 2.0 effort. Specifically, it has been argued that Pillar 2 (and especially the UTPR) is inconsistent with US tax treaties, that Pillar 2 is not needed to address profit...