Law360 Quotes David Rosenbloom New Global Tax Rules

Countries are in the final stages of negotiating a corporate tax plan that would reallocate taxing rights among jurisdictions — a policy overhaul that could face roadblocks to implementation, including an existing treaty network that's based on a 100-year-old system.

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On the global level, there's currently only a tentative agreement setting out general terms, according to David Rosenbloom, a member of Caplin & Drysdale. 

"Tax laws are very specific," he said. "We've got a long way to go to translate what's been discussed so far into an actual statutory proposal."

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As Rosenbloom at Caplin & Drysdale saw it, "getting the Senate to approve a multilateral treaty would be even harder than getting it to approve a normal bilateral treaty."

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President Joe Biden's administration only has a fairly limited period of time to come forward with a reconciliation bill for Pillars One and Two, according to Rosenbloom at Caplin & Drysdale. And a reconciliation bill is the only way this measure can be passed under the current dynamics in the Senate, he said.

"I would be astonished if there were an agreement reached on the OECD proposals in time to enter into the reconciliation package with any degree of detail," he said. "The timing on this doesn't seem to me to be conducive to using reconciliation to further anything like Pillar One and Pillar Two."

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