Mindy Herzfeld (Florida), Revived Digital Discussions? Just Don’t Call It Amount A , 121 Tax Notes Int’l 1135 (Feb. 16, 2026):

With multilateral agreement on an approach to pillar 2 that acknowledges that global intangible low-taxed income (now net controlled foreign corporation tested income) should be considered equivalent to the global minimum tax outlined by the OECD in its model rules, the focus has turned to reviving discussions about taxation of the digitalized economy. Possible solutions — initially prioritized as action item 1 in the OECD’s base erosion and profit-shifting project, and later morphing into the amount A proposal of pillar 1 of the OECD’s phase 2 project for taxing the digitalized economy — have remained elusive. The success of future efforts depends, at a minimum, on clearly articulated goals and an examination of why previous attempts failed.