June 20, 2024: A Date that Will Live in Tax Infamy

On June 20, 2024, three events transpired that have potentially momentous tax effects on Canadian, US, and certain other countries’ mega multinationals. In Canada, there was the passage of two laws: (1) the controversial (3%) Digital Services Tax Act that is considered a major concern to US interests, and (2) the radical Global Minimum Tax Act (containing two thirds of the October 8, 2021, 137-country-agreed Pillar Two approach) adopting a global 15% minimum tax for multinationals that have at least €750mm of annual revenue. (The two thirds are the “income inclusion rule” that would tax a Canadian parent on undertaxed ...