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hello Im Bob Golder contributing editor with tax notes welcome to the latest edition of In the pages where we take a closer look at some of the commentary from our print and online Publications now if you follow International tax policy at all you might know that there is a raging debate going on these days it concerns a particular aspect of the oecds pillar 2 proposal for Global tax reform specifically the utpr or under taxed profits rule the tax Community is basically split as to whether this rule violates International tax Norms or treaty obligations or whether it complies with them uh tax notes has published uh multiple articles on this topic and I think perhaps the best one was written by uh our guest speakers today conveniently the article is titled under tax profits and the use it or lose it principle and the co-authors are Allison Christians and tarcissio dines Professor Christians is with McGill University in Montreal where theres a lot of snow uh and Mr regalis is an assi