The Impact Of The 2020 U.S. Elections On International Tax

Tax Notessenior authorized reporter Andrew Velarde and contributing editor Robert Goulder talk about the affect of the 2020 U.S. elections on the worldwide tax world.

This publish has been edited for size and readability.

David Stewart:Welcome to the podcast. I am David Stewart, editor in chief ofTax Notes At the moment Worldwide. This week: going worldwide. Because the states certify the outcomes of the 2020 U.S. presidential election, the world is anticipating how a Joe Biden presidency will have an effect on worldwide relations and overseas coverage. A change in administration may additionally lead to a shift in U.S. worldwide tax coverage, simply because the worldwide neighborhood is working to overtake the worldwide tax system for the digital age.

In a while, we’ll speak toTax Notescontributing editor Robert Goulder about what the incoming Biden administration means for the OECD’s digital economic system mission. However first, this isTax Notesreporter Andrew Velarde to debate the affect of President-elect Biden’s insurance policies on U.S. worldwide taxation.

Andrew, welcome again to the podcast.

Andrew Velarde:Hello, Dave. Good to be speaking with you.

David Stewart:What insurance policies have we seen from Joe Biden as he was working for president?

Andrew Velarde:Joe Biden’s fundamental theme right here he has a plan touted as a option to get multinationals to pay their justifiable share. We have seen some particulars on the market, though it leaves lots to be absolutely fleshed out. There’s calls to boost the company price to 28 % from its present 21 %. On prime of that, he is proposed an offshoring penalty surtax of 10 %. That form of revenue would face a price at 30.eight %.

Then there is a provision for a 15 % company minimal tax on e book revenue. It is unclear how that may be outlined. That is relevant to firms making no less than $100 million in earnings. You’ll be able to form of consider this as a sort of different minimal tax.

There’s additionally a provision for tax credit score to deliver manufacturing again to the U.S. and a few slightly obscure statements about tightening inversion guidelines. The theme of this usually is that, and you are going to hear this from me lots throughout this speak, there’s a variety of particulars lacking from this. A variety of the main points we do have got here from a marketing campaign doc in September, but it surely’s a marketing campaign doc. It is not in-the-weeds tax coverage, but it surely’s a leaping off level.

David Stewart:One of many greatest adjustments we have seen within the final a number of years has been the Tax Cuts and Jobs Act. In that, we ended up with this new idea of GILTI, the worldwide intangible low-taxed revenue provision. Democrats have talked about eliminating the TCJA. Do you count on that Biden will attempt to undo or drastically change any of the worldwide provisions?

Andrew Velarde:I believe you are going to see some substantial modifications on the very least. GILTI is definitely the place we have now among the most element from the Biden upcoming administration.

Below part 951A, every U.S. shareholder of a managed overseas company is topic to tax on GILTI, which is outlined as the surplus of its professionalrata share of examined CFC revenue over a 10 % return on its professionalrata share of the depreciable tangible property of every CFC. That final aspect referred to as certified enterprise asset funding, or QBAI.

Now there is a pressure between whether or not to start out from scratch or considerably modify the TCJA. We have gotten extra particulars on these GILTI adjustments by the Biden administration. There are a number of prongs to those adjustments. For some time now, Biden has talked about modifying the speed on GILTI to go from 10.5 % to 21 %. GILTI is taxed at a decrease price than the final company price of 21 % at the moment. Biden needs to double that.

He needs to maneuver to a country-by-country dedication when inspecting the speed. In these most up-to-date marketing campaign paperwork, he has language in there that would appear to counsel eliminating the exemption for the deemed returns underneath 10 %, the QBAI that I referred to earlier.

The results of those adjustments might be big, however the actual quantity is tough to pin down. The Tax Coverage Heart has modified their estimates of those adjustments considerably as extra particulars have come out, and it began estimating again in March round $300 billion. It is jumped as much as $705 billion once they estimated it in October. The Tax Basis’s been just a little extra in line with their estimates on how a lot income it will increase: round $290 billion. All these numbers are over the course of 10 years. Regardless although, it’s in all probability slated to be one of many greatest income turbines.

With these GILTI modifications which might be put into place, one other factor to think about is many multinationals might not face the minimal e book tax I talked about earlier.

A ultimate aspect I might wish to level out is that this was a marketing campaign doc. They’ve oversimplified GILTI. They’ve simply referred to as GILTI a doubling the speed from 10.5 % to 21 %. GILTI is extra sophisticated than that. It begins with a 10.5 % price, however there is a overseas tax credit score haircut. They solely permit 80 % of your FTCs,which implies incomes might be taxed at 13.125 %.

On prime of that, there are expense allocation guidelines, which may additional cut back the cap for FTCs. We do not understand how Biden will tackle this. It is not in something public that is come out, however there’s risk for change there as effectively.

David Stewart:Are there any hints at what the incoming administration would possibly do about different provisions, equivalent to BEAT, the bottom erosion anti-abuse tax, or FDII, the foreign-derived intangible revenue provision?

Andrew Velarde:Positive. These are two of the principle new provisions that got here out of the TCJA. The plan is silent on these. I believe that is just a little fascinating, particularly since FDII is intently tied with GILTI. FDII is the carrot to the GILTI stick. FDII’s designed to draw intangibles with a deduction, encouraging intangibles to be introduced again to the U.S. They’re each tied to the identical part 250 when calculating their deduction.

However there are arguments on the market although from some outstanding economists in opposition to maintaining FDII as a result of it encourages the offshoring of bodily belongings in the best way it is calculated. These arguments may doubtlessly be in step with Biden’s common philosophy of making an attempt to encourage onshoring of jobs, of belongings, of issues like that. It is one thing that bears watching, however we have now no hints at what the administration truly can be contemplating with FDII.

There’s additionally no dialogue about what is going to occur with BEAT. That provision is fascinating as a result of it is one of many few provisions from the TCJA that truly goes after overseas multinationals, not simply U.S. multinationals. Earlier than the TCJA, U.S. multinationals would usually complain that they are at a aggressive drawback when in comparison with their overseas counterparts. One may envision them making related complaints if the speed goes up once more and if GILTI will get extra harsh.

The potential response to that might be to strengthen BEAT since that additionally applies to overseas multinationals. I am positive a variety of firms wouldn’t be pleased about that, however that could be a potential response.

David Stewart:What are you listening to from folks within the worldwide tax neighborhood? Any reactions?

Andrew Velarde:It is a bit too early for planning. As I mentioned earlier than, there’s a variety of particulars lacking from these items. Nevertheless, it is not too early for firms, for executives, to start out placing this on their radar and even to start out modeling.

If executives and practitioners are actually in search of the place this plan would possibly go and have extra particulars, I’ve talked to a number of people which have advisable trying again to the outdated Treasury inexperienced books from the Barack Obama administration. These are the main points that got here out at the side of the Obama budgets yearly. The latest yr was fiscal yr 2017. There’s a variety of particulars there and the quantity of overlap doubtlessly might be important. I say “doubtlessly,” as a result of we do not know for positive.

For instance, within the fiscal yr 2017 funds and in earlier years as effectively, there’s a proposal for a minimal tax on CFCs and branches at 19 %, minus 85 % of a per nation overseas tax price. Albeit decreased for an allowance for company fairness representing risk-free return invested in lively belongings.

Now let’s take a step again. That final half sounds an terrible lot like QBAI, and talking extra usually, it sounds just a little just like GILTI. We’ve got Biden reversing course and calling seemingly for the elimination of the QBAI exemption. It is one thing price watching as a result of it is clearly not going to come back out of the ether right here, no matter will get chosen or no matter path they transfer in.

These inexperienced books additionally referred to as for inversion rule tightening. We’ve got a one throwaway line in that marketing campaign doc. We’ve got much more element in these Treasury inexperienced books. Broad brush strokes, these inexperienced books referred to as for tightening of these inversions by reducing the continued possession threshold for what qualifies as an inversion.

When a much bigger U.S. firm acquires a smaller competitor and redomiciles to a different overseas nation, at the moment to be an inversion and miss out on a variety of the tax advantages of that, it is 80 % or larger continued possession threshold for the homeowners of the U.S. firm. The inexperienced e book proposed to decrease that to 50 %, so a considerable drop. That may be key as a result of a variety of these inversions would have an possession threshold of U.S. homeowners someplace between the 50 % and 80 % threshold.

David Stewart:As we’re recording this, the Senate is no less than 50 Republicans and 48 Democrats, with a runoff election in January. We’re taking a look at the opportunity of a Republican-controlled Senate and Democratic-controlled White Home and Home. That looks like it’d make it tough to get legislative adjustments by. Are there any form of regulatory adjustments that might be made?

Andrew Velarde:Actually. You are referring to the runoff elections in Georgia. If the Democrats take each of these seats, then it’s going to be a 50-50 Senate and the Biden administration would have the tie breaker. If that does not occur, you are proper. There’s important roadblocks doubtlessly.

On prime of that, there’s additionally considerations over elevating taxes throughout financial struggles with COVID-19 occurring. There’s additionally wants for COVID-19 aid. A variety of which means tax laws might not rise to the highest of the to-do record, no less than not once they first are available in.

That leaves the regulatory motion. We have seen a variety of worldwide steering in the previous few months with the promise of extra to come back. Simply to get a small number of that, the all-important FTC regs got here out only a few months in the past. The BEAT waiver, this could be a provision that may permit taxpayers to waive deductions to be able to keep away from the BEAT altogether. The BEAT can be inapplicable to them.

We noticed a couple of months earlier than that regs on the GILTI and subpart F high-tax exclusion high-tax exception. Simply to degree set just a little there, the high-tax exclusion would allow an exclusion from examined revenue of quantities taxed at 90 % of the U.S. price. That may change. Proper now, it is 18.9 %. If the company price goes up 28 %, that may go up as effectively.

The regs that we see now, they transfer to adapt the subpart F high-tax exception with the GILTI high-tax exclusion. I draw specific consideration to this one as a result of I’ve talked to some specialists that suppose that this one particularly may bear watching. Again in February, Sens. Ron Wyden, D-Ore., and Sherrod Brown, D-Ohio,launched a invoice referred to as the “Blocking New Company Tax Giveaways Act,” which is seeking to cast off the high-tax exclusion on GILTI. That’s within the rules now. I believe we should always hold a detailed eye on that underneath the brand new Biden administration.

One other regulation that may bear watching in addition to the part 385 fairness documentation guidelines. These had been completed away with. These may probably be reinstated as effectively.

Lastly, simply one thing to maintain a watch out for can be the opportunity of a short lived regulatory freeze when the Biden administration is available in in January. That is when the brand new administration is available in. They’re placing of their folks. They wish to evaluation every little thing that is at the moment being labored on earlier than truly pushing out extra steering. These are non permanent stops of what is getting pushed out within the federal register. This was completed by each Obama and Trump once they got here in. It could not be stunning if Biden did the identical.

David Stewart:Nicely, Andrew, this has been nice. Thanks for being right here.

Andrew Velarde:Thanks, Dave. It has been good speaking with you.

David Stewart:Now, we’ll flip to the election’s potential affect on the OECD’s digital economic system mission. I am joined byTax Notescontributing editor Robert Goulder. Bob, welcome again to the podcast.

Robert Goulder:Thanks for having me, David.

David Stewart:Earlier than we actually get into it, may you inform us the place the digital economic system mission at the moment stands?

Robert Goulder:Sure. It stands at a really fascinating level as a result of they had been speculated to be wrapping issues up by the top of this calendar yr. They realized, “Nicely, we’ll should push it just a little bit down the highway, however not too far.” That isn’t the worst factor.

No matter what you consider pillar 1, pillar 2, the financial assessments, and so forth, you’d want to provide them a heck of a variety of credit score for simply maintaining on the timeframe. It is such an bold mission right here. Simply that they’ve come this far outstanding.

With the blueprint that got here out in October, we all know just a little bit extra about pillar 1 and pillar 2. For many who do not know, pillar 1 is about new taxing rights and revenue allocations for market jurisdictions. It is actually form of radical stuff, I believe, as a result of we’re speaking overtly right here about formulary apportionment ideas. You’ve got your quantity A and your quantity B, and we realized that quantity C went away, but it surely was by no means actually a lot of an quantity anyway.

There’s nonetheless an entire lot of questions that individuals are asking about quantity A. I imply, I’ve points with this scope. Numerous folks have points with the quantum. All that also needs to be labored out over the following coming months till they lastly say, “OK, right here it’s. BEPS 2.Zero is completed. That is the factor you are taking a look at.”

What they should do between at times is determine is that this residual quantity. If you’ve acquired an enormous multinational company and cash is fungible, and also you’re trying on the accounting statements or the tax returns, you are going to have to tell apart between regular returns and residual returns.

I believe these are issues which might be going to perhaps be a clumsy match for the tax situation. They appear like rubber numbers to me. You are going to want some actually tight guidelines to pin down, “What is that this quantum?” As a result of individuals are going to wish to recreation it.

For those who do not like what occurs with quantity A, you then’re simply going to play video games with this quantum and say, “OK, this factor we do not like goes to be taking place to an ever reducing pot of cash, as a result of we’re simply going to say, ‘There’s not a lot of the residual return left. It is all regular return.’” That is on the market.

Then, pillar 2, I will suppose is just a little bit much less delicate. It is a international minimal tax. Once more, that’s form of radical within the sense that 20 years in the past no person was doing it and no person was even speaking about doing it. However right here we’re.

The worldwide minimal tax is one way or the other the least controversial of the 2 pillars. You have acquired these 4 interlocking guidelines. We have all been studying in regards to the revenue inclusion rule, the underneath tax cost rule, topic to tax rule, a switchover rule.

Once more, with the blueprint, we all know just a little bit extra about them. The switchover rule has form of been integrated into the topic to tax rule since you’re trying on the treaty context there. What I am listening to about once I speak to folks about is what’s nonetheless on the market that is getting folks to scratch their heads with pillar 2 is that this reliance on a typical tax base for the multinational group utilizing monetary accounts. “Wow, what are we doing with that?”

Think about a situation the place you will have an enormous company they usually wish to talk to Wall Road. They are saying, “Come spend money on us as a result of we’re nice. Purchase our inventory. Listed below are monetary accounts to indicate you ways worthwhile we’re.” Then folks from the tax division are going to say, “Whoa, whoa, whoa. Placed on the brake. Do not launch these issues. We have to fiddle with these numbers lots. We do not wish to be declaring an excessive amount of revenue in our statements as a result of we’ll be taxed on that underneath pillar 2.”

The query you get at that I believe is fascinating and I do not know if there is a agency reply there is what goes into your taxable revenue calculated underneath the Inside Income Code, or what goes into your monetary statements?

I used to suppose earlier than BEPS 2.0 that there was extra objectivity with monetary accounts, and that may be an awesome supply for company tax base or perhaps a company AMT for those who based mostly it on monetary accounts. That may be nice as a result of it is extra goal and fewer liable to manipulation.

Now I am pondering, “Nicely, wait a minute. Not likely. Possibly the monetary accounts are literally the extra malleable of the 2.” That is acquired lots of people scratching their heads.

Is any of this actually going to occur? Below Treasury Secretary Steven Mnuchin, you continue to have this concept of the entire thing being a secure harbor, or no less than pillar 1 being a secure harbor. For those who’re an American, you do not have to fret an excessive amount of about pillar 2 being a secure harbor as a result of is not that first rule, the revenue inclusion rule, an entire lot like GILTI underneath TCJA? It addresses the outbound alternative for revenue shifting. Is not the undertaxed cost rule form of just like the BEAT that got here in underneath TCJA? It addresses the inbound alternative for revenue stripping.

Possibly pillar 2 is just not a secure harbor, however underneath Mnuchin, it completely is. They need pillar 1 to be a secure harbor, which means you’ll be able to choose into it, which means perhaps no person ever opts into it.

David Stewart:The present administration’s place on that is considerably clear. Biden can be transferring into the White Home on January 20. What, if something, do you count on to alter within the U.S. place as the brand new administration takes over?

Robert Goulder:Dave, right here is my scorching take for this podcast. Every little thing within the recognized universe goes to alter if you go from the Trump Treasury to the Biden Treasury, besides the views on BEPS. That is due to the basic nature of company America and notion of defending your nationwide champions.

I truly went again and listened to apodcastyou recorded with Bob Stack. Stack was the U.S. Treasury Division’s level man on BEPS model 1.Zero within the Obama years. What struck me is that he was saying issues that simply sound level for level parallel to what Chip Harter, the purpose man for the Treasury now underneath Trump, has to say. The shortage of conceptual differentials between what you’ll hear from Stack and what you’ll hear from Harter actually makes me suppose that that is simply going to proceed.

When all of the mud settles, nothing’s actually going to alter. It may not be at some flashy information convention. It could be buried in a footnote. However sooner or later, U.S. Treasury Division underneath Biden will say, “Yeah, it must be a secure harbor.”

David Stewart:We’re at the moment in a transition interval. There may be going to be a successor to Chip Harter sooner or later. However the present administration is just not cooperating within the transition interval. Does which have a possible for delay or simply messing up the changeover to whoever the brand new level particular person goes to be?

Robert Goulder:I’m reminded of that outdated adage: By no means let an excellent disaster go to waste. What we have now right here would not rise to the extent of a constitutional disaster, but it surely’s an enormous downside. All kinds of parallels are being drawn to the 9/11 report, which mentioned that there have been points due to the entire Bush v. Gore factor. When you do not have a clean transition, there’s ripple results that we won’t even anticipate.

Individuals are going to come back into Treasury and they will be delayed. They cannot hit the bottom rolling due to these transition points. To the extent that could be a disaster, it may and may and can be used to push issues again even additional.

All these things in regards to the completely ultimate BEPS 2.Zero determinations and consensus paperwork popping out mid-2021 push that again to the top of the calendar yr 2021. It feeds into what I mentioned earlier than: The U.S. nonetheless would not like this. Silicon Valley, our tech companies aren’t going to love this. You’ll be able to’t assist however take a look at all these things in regards to the digital economic system and say, “It actually looks like a brand new tax on American multinationals.”

David Stewart:For those who had some recommendation to provide the OECD and the inclusive framework on how they need to be making ready for the brand new administration, what would you inform them?

Robert Goulder:Nicely, there’s two ranges of recommendation. There’s the type that I might give them formally on the document with my tie completed up after which there’s the extra frank, salt of the earth recommendation that I might give them.

The salt of the earth recommendation that I might give them is take among the assets that you just’re placing into the entire digital economic system train and as a substitute attempt to develop pointers on what a mannequin digital providers tax ought to appear to be. As a result of that is the place we’re headed.

We’ll have DSTs. They don’t seem to be going to go away. They are going to get greater. The charges are going to go up. If a rustic would not have a DST, what are they doing? What are they ready for? Get with it, guys. These are going to have lasting energy.

As a result of even when by some quirk the U.S. indicators onto this, it is going to take years for it to be carried out and get by Congress. We simply had the TCJA. With congressional gridlock, you suppose all that is going to occur?

Throughout all that point, these different international locations are going to be getting DSTs. Possibly the EU will wait, as a result of there’s been an announcement from the EU that they will respect the OECD timeline. However international locations are going to be doing it on their very own. France goes to start out gathering in December. The UK will start gathering in December. Spain begins in January. They’re simply going to get greater and bolder. The African Tax Administration Discussion board has been releasing pointers for the way African nations ought to begin doing this. Everyone seems to be leaping on the bandwagon.

It will be like VAT, the place each nation on the earth, aside from the U.S., has a VAT. I can see a situation the place each nation on the earth has a DST, aside from America. There is a parallel there. How about encouraging these international locations to enact DSTs which might be much less disruptive and are higher designed? There is a vary of what we’ll see are good DSTs and unhealthy DSTs. Why not push governments to enact good ones? It is a vacuum that must be stuffed. That is what I believe the OECD ought to be doing.

The formal recommendation as to what they need to be doing to organize for the following administration is the necessity to perceive the American mindset. We’re an financial superpower, so there’s this tendency for us to wish to push every little thing right into a tariff field. If anyone enacts a tax that we do not like, and it seems like a tariff, we wish to reply by placing tariffs on them. That is a really Trumpian factor to do, but it surely does comply with from being an financial superpower.

I might inform the OECD: Be ready to elucidate to the Biden Treasury why these taxes aren’t discriminatory and why DSTs aren’t actually trying like tariffs. Clarify to them why this is not a case of the entire world ganging up on us.

David Stewart:We’ve got seen the Trump administration threatening tariffs in opposition to all of those international locations which might be imposing DSTs. Do you count on any form of softening in that place underneath a Biden administration?

Robert Goulder:Sure. There can be some softening, but it surely’s a sort of softening that could be a bit superficial.

Here is what I imply: I do not suppose that the Biden administration is something like what the Trump administration was with its fondness for tariffs. You bought the sense that the Trump administration took some visceral pleasure from making use of tariffs to imports.

One factor I believe we are able to count on the Biden administration to do is raise the metal and aluminum tariffs underneath the brand new U.S. commerce consultant that is available in. That is to not appease folks in different international locations. Lifting the tariffs is just not a case of being good to some foreigner. It helps U.S. companies develop and be aggressive.

David Stewart:Along with the metal tariffs, do you see any form of unwinding of the tariffs that we have now in place at this level? There’s been a variety of forwards and backwards in regards to the Boeing-Airbus dispute. Is there room for a Biden administration to tug again on a variety of the tariffs that we have seen over the previous few years?

Robert Goulder:Completely. What you wish to do is do away with them, assuming that there is going to be reciprocity there. Our exports to overseas markets are being punished and made uncompetitive as effectively. There’s a lot of people within the U.S. farm belt that want to see different international locations like China decrease their tariffs that had been imposed in retaliation to ours.

David Stewart:You mentioned that you just wish to see the OECD provide you with a mannequin DST. Is there a world the place the U.S. can settle for a extra common use of DSTs world wide?

Robert Goulder:I definitely can see that world. I truly suppose that DSTs get a foul rap. Within the tutorial and mental scholarly neighborhood, DSTs get no love in any way. I really feel a bit out on an island once I’m positioning myself as a man who says good issues about DSTs. It’s a tax on turnover. It’s a gross receipts tax, and that could be a horrible tax. Let me get that out of the best way proper now.

Additionally, it is a tax that may truly be paid, collected, and responds to political pressures. All tax is political. Proper? We should not have tax codes and rules which might be introduced collectively purely by lecturers who suppose, “Oh, that is the perfect coverage. That is optimum coverage. Let’s do that.” We get tax legal guidelines on account of politicians who should fundraise. Our tax legal guidelines are written by people who find themselves perpetually campaigning.

The strain in Europe to have taxes that hit these firms and appear to be they’re falling on capital revenue is basically nice. That strain is just not one way or the other novel or new. All politics is form of inherently motivated by these political needs. To dismiss a tax as a result of it has political motivations simply looks like some ivory tower notion that has what foundation?

That situation that you just talked about the place the U.S. can settle for that is as follows. If it truly is a tariff and to illustrate the economics of a DST mirror that of a tariff you go it onto the ultimate shopper. Who’s consuming the digital providers supplied in France? Or the digital providers supplied within the U.Okay. or Germany or any nation with a DST? You must go it on to the shoppers.

If Netflix will get hit with a DST, they usually’re in a position to go all of it on to shoppers. Then the shoppers in these international locations, which isn’t the U.S., aren’t our shoppers. It is anyone else’s shoppers.

If that turns into firmly established, that the burden of the DST is not falling on the shareholders of the U.S. tech sector, then perhaps they’re high-quality with this. It is simply one other price that will get handed on. After all, if that is actually the case, why do not the opposite international locations be intellectually trustworthy about it and mainly deal with it with a VAT? As a result of if it does fall on the ultimate shopper, there isn’t any distinction between a DST and a VAT.

However once more, the political strain is that the optics of getting European shoppers pay the European DSTs is simply unacceptable. They can’t dwell with these optics. They want the form of fig leaf that it is a tax on an enormous wealthy company on the market in Silicone Valley, that it is falling on capital revenue.

David Stewart:We have coated what you are hoping for. What do you truly count on? Over the following 12 months, what kind of adjustments do you count on to see from the U.S. in its worldwide tax coverage? What kind of settlement do you suppose that the OECD can produce?

Robert Goulder:I’ve a sense that the U.S. nonetheless is not going to go together with any of this. What I believe is definitely going to occur is that every little thing will get delayed to the top of the calendar yr 2021. We very politely say, “Yeah, we’ll be OK with pillar 2, however we won’t do pillar 1.”

That seems like defeat as a result of a lot power and assets has gone into this. The entire level of BEPS 2.Zero was to provide these new taxing rights to overseas jurisdictions and allow them to have a few of these residual earnings which might be so fascinating. If pillar 1 falls by the wayside, are they actually getting that?

However once more, let me say this: 20 years in the past, a worldwide minimal tax that in and of itself was radical. That is a daring factor. When all of the mud settles and the world has pillar 2, however we simply could not work it out on pillar 1, as a substitute of claiming, “That is a glass half empty,” I will say, “That is a glass half full.” I believe what we’ll have is simply consolidation across the want for a worldwide minimal tax.

David Stewart:Nicely, on that optimistic notice, we’ll depart it there. Bob, thanks for being right here.

Robert Goulder:My pleasure, Dave.

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