Elizabeth Stevens Speaks to Bloomberg Tax on Pillar One

Increased audits of big companies and high wealth taxpayers, developments on several tax disputes before the US Supreme Court, an $80 billion boost in IRS funding, and more procedural fights against IRS rulemaking are among some of the big issues in tax for 2023.

Here’s what to watch for next year.

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International Tax Disputes and Multinationals

The new year includes the planned implementation of Pillar One, the first part of the OECD-led global tax deal. Pillar One will tax companies in countries they do business in, even if they don’t have a physical presence. Elizabeth Stevens, who practices in international tax issues at Caplin & Drysdale, is bearish on the implementation of Pillar One in 2023.

“The OECD has devoted colossal energy and technical effort to developing proposed rules and all of these discussion drafts, but 2023 is really when the implementation was expected to happen, and I really don’t see that happening,” said Stevens, noting a resurgence in digital service taxes by some jurisdictions in lieu of the framework.

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