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The Multilateral Convention to Implement Amount A of Pillar One (MLC) released in October 2023 is the culmination of work addressing tax challenges related to the digitalized economy carried out by delegates of the Inclusive Framework member countries. In their article “Amount A Impact Analysis on US Corporate Tax Revenue—A 2024 Update” published in Tax Notes International, Managing Director Vladimir Starkov and Consultant Alexis Jin assess the effect of the Amount A regime defined in the draft MLC on US corporate income tax revenue, using sources of information available to private sector researchers. Dr. Starkov and Ms. Jin demonstrate the hypothetical effect of Amount A on US corporate tax revenues by identifying and examining 100 multinational enterprises likely to be in scope of Amount A.

Based on the in-scope companies’ 2022 financial data, their analysis concludes Amount A’s effect on US corporate income tax revenues may be mildly positive in the initial years of the Amount A rollout (up to $11 billion per year or less than 3% of the total amount of the US corporate tax revenue collected annually). However, this positive effect will likely diminish in later years because of the proliferation of the Pillar 2 global minimum tax regime.

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