In Law360’s roundup of key international tax issues to watch in the second half of 2025, Professor Zhaoyi Li of Albany Law School commented on the U.S. Treasury’s push for a “side-by-side” system that would exempt U.S. companies from the OECD’s 15% global minimum tax. She noted this approach could give American companies a compliance advantage, as they would have fewer documentation requirements and lower associated costs.
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