Secretary Yellen is pushing for a global minimum tax rate for multi-national corporations. This is all part of the discussion regarding President Biden’s $2.3 trillion infrastructure program. Many countries, such as Ireland, have very low tax rates which obviously draw multi-national corporations to their shores to take advantage of these rates, and in particular, intellectual property can easily be parked in those jurisdictions with royalties paid by the parent entities to the Irish corporation, and thus, we see dramatically reduced overall tax bills associated with these transactions. Taking Ireland as an example, would it agree to a minimum tax rate which was significantly higher than the one they currently utilize to attract business, seems somewhat unlikely to me unless there is another carrot out there which is being offered. The pitch being made by Ms. Yellen is best summarized in the following quote from her subsidiary: “It is about making sure that governments have stable tax systems that raise sufficient revenue to invest in the central public goods, and respond to crisis, and that all citizens fairly share the burden of financing government.” This is certainly a lofty proposition, and it will be interesting to see how it is not only received, but acted upon, or not to.