Kaitlin Gray Kaitlin Gray

OECD releases guidance for Pillar Two, including GILTI coexistence and QDMTT design

The OECD released administrative guidance for implementing the global minimum tax under Pillar Two, including GILTI coexistence and QDMTT design.

TPM-02R: Transfer-Pricing Secondary Adjustments and Repatriation

TPM-02R replaces Transfer Pricing Memorandum TPM-02, “Repatriation of Funds by Non-Residents—Part XIII Assessments,” and certain paragraphs...

OECD/G20 Inclusive Framework reaches high-level agreement on two-pillar approach to international tax reform

In their Osler Update, authors Patrick Marley, Peter Macdonald, Kaitlin Gray and Taylor Cao comment on the statement by the OECD/G20 Inclusive...

G7 Finance Ministers back international tax reform (Pillar One and Pillar Two), including introducing a global minimum tax of at least 15%

On June 5, 2021, the Finance Ministers from the G7 group of leading economies (including Canada) committed to the principal design elements for the...

Osler submission on the OECD Pillar One and Pillar Two Blueprints

Earlier in 2020, the OECD published blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar...

COVID-19 tax measures and proposed international tax reform

Two significant tax developments in 2020 were Canada’s measures in response to COVID-19 and Canada’s participation with the OECD’s pursuit of...

OECD releases blueprint reports on international tax reform (Pillar One and Pillar Two) and launches public consultation

The OECD recently released blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar approach to...

OECD provides additional detail on Pillar One proposal in update on international tax reform – Seeking consensus-based solution in 2020

On January 31, 2020, the OECD/G20 Inclusive Framework on BEPS released the Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar...

International tax: A year of transition

In 2019, global efforts towards international tax reform – spearheaded by the G20 and the OECD – continued to move forward. Two developments in...

Osler submission to OECD advocates for narrow application of Global Anti-Base Erosion Proposal

Osler has made a submission to the OECD advocating that the GloBE Proposal should be applied narrowly, and should only proceed once a strong...