24th Annual U.S. and Europe Tax Practice Trends Conference

Sam Kaywood will co-chair the panel “Pillar Two: How Solid Is the UTPR?” at this event hosted by the American Bar Association’s Tax Section. The panel will discuss the mechanics for application of the UTPR, the timing (as of when applicable), how it works under the EU Pillar Two Directive, what other countries outside the EU will go for it, the position of the United States and the compatibility with tax treaties, bilateral investment treaties, and constitutional rights.