The Book Minimum Tax: The Latest (and Greatest?) in Tax Policy
Tax Attorney Joshua Odintz authored a Knight Watch column in The Tax Magazine about the largest tax increase in the Inflation Reduction Act, the Book Minimum Tax (BMT). In this article, he discusses the architecture of the BMT and shares how the new tax should interact with the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar Two. The BMT does not have a robust legislative history since it was not marked up in either tax writing committee. Additionally, the House Ways & Means work product and various House committee reports do not describe the BMT. Consequently, Mr. Odintz concludes that the Treasury will need to divine Congressional intent as it works to address outstanding questions.
This is Part 1 of 2. You can read Part 2 authored by Lee Meyercord and Jackson Oliver here.