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One Small Step but (Perhaps) One Giant Leap for Global Tax Reform: The G7 Agrees on a Broad Framework for Pillar One and Two

By Michael Lebovitz, Jenny A. Austin, Warren S. Payne, Kenneth Klein, Lucas Giardelli, Astrid Pieron & Tyler M. Johnson on June 28, 2021
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On June 5, 2021, the Finance Ministers and Central Bank Governors of the G7 countries issued a Communiqué announcing their agreement on the conceptual framework for a substantial revision to global tax policy (the “Communiqué”). The Communiqué puts the G7’s stamp of approval on recent efforts by the OECD (supported by a big push by the Biden administration) toward finalizing the broad architecture of the OECD’s Pillar One and Two models. The Communiqué will form the basis of continued negotiations by the Inclusive Framework (IF) on June 30 and July 1, followed by final negotiations by the G20, which meets on July 9 and 10, at which time the G7 hopes that a final agreement will be reached.

But there is still much work to do to flesh out the details of the framework. In our recent article, we unpack the Communique’s discussion on taxes and provide our perspective on what has been agreed to and our observations on what issues remain and whether they can be resolved.

Click here for the complete article.

Also, on July 15, we will be hosting a webinar to discuss these developments and an analysis of the Biden administration’s international tax proposals that complement some of the G7 proposals.

Photo of Michael Lebovitz Michael Lebovitz

Michael Lebovitz is a partner in Mayer Brown’s Tax Transactions & Consulting practice. Mike advises on the tax aspects of international joint ventures, cross-border mergers and acquisitions, post-transaction integration, international corporate finance, capital market transactions and general international tax planning matters across multiple…

Michael Lebovitz is a partner in Mayer Brown’s Tax Transactions & Consulting practice. Mike advises on the tax aspects of international joint ventures, cross-border mergers and acquisitions, post-transaction integration, international corporate finance, capital market transactions and general international tax planning matters across multiple industries including life sciences, media and entertainment, telecom, technology, oil and gas, and industrial and consumer products.

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Photo of Jenny A. Austin Jenny A. Austin

Jenny Austin is a partner in Mayer Brown’s Chicago office and a member of the Tax Controversy practice. She concentrates her practice on federal tax controversy and litigation, working across all industries, including medical device, pharmaceutical, health care, retail, and technology companies. She…

Jenny Austin is a partner in Mayer Brown’s Chicago office and a member of the Tax Controversy practice. She concentrates her practice on federal tax controversy and litigation, working across all industries, including medical device, pharmaceutical, health care, retail, and technology companies. She guides clients through all stages of tax controversies, from Internal Revenue Service (IRS) audits to administrative appeals, alternative dispute resolution proceedings, and litigation. Jenny is prepared to respond to a variety of both domestic and international issues that the IRS audits and challenges. Jenny favors strategies to resolve issues successfully with the IRS at the earliest possible stage without litigation.

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Photo of Warren S. Payne Warren S. Payne
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Photo of Astrid Pieron Astrid Pieron

Astrid Pieron’s practice covers counseling on the transactional aspects of transfer pricing, tax optimization of mergers and acquisitions, structuring of investment funds and general assistance to private equity deals.

Astrid is heading the Mayer Brown European transfer pricing center that coordinates transfer pricing…

Astrid Pieron’s practice covers counseling on the transactional aspects of transfer pricing, tax optimization of mergers and acquisitions, structuring of investment funds and general assistance to private equity deals.

Astrid is heading the Mayer Brown European transfer pricing center that coordinates transfer pricing strategies and controversies in Europe. She served as a non governmental member to the EU Joint transfer pricing Forum advising the EU commission on transfer pricing matters (2012-2015). She currently serves as a Member of the EU Platform for Good tax Governance advising the EU commission on the BEPS implementation.

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Photo of Tyler M. Johnson Tyler M. Johnson

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  • Posted in:
    Tax
  • Blog:
    Best Methods
  • Organization:
    Mayer Brown
  • Article: View Original Source

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